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U.S. v. Gateward

United States Court of Appeals, Third Circuit
May 24, 1996
84 F.3d 670 (3d Cir. 1996)

Summary

holding the interstate commerce nexus of § 922(g) is established through proof the subject firearm had previously traveled in interstate commerce

Summary of this case from U.S. v. Blackman

Opinion

No. 95-1839.

Submitted May 20, 1996.

Opinion filed May 24, 1996.

John T. Drost, Esq. Philadelphia, PA 19107 Attorney for Appellant.

Michael R. Stiles, United States Attorney, Walter S. Batty, Jr., Assistant United States Attorney, Clement J. McGovern, III, Special Assistant United States Attorney Attorneys for Appellee.

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 94-cr-00154).

Before: SLOVITER, Chief Judge, SAROKIN and ROSENN, Circuit Judges.


Appellant Kenneth Gateward was convicted after a jury trial for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1). Gateward challenges the constitutionality of that statute as beyond Congress' regulatory power under the Commerce Clause.

I.

Gateward was indicted by a federal grand jury on a single count of possession of a firearm by a convicted felon. Such possession is prohibited under 18 U.S.C. §(s) 922(g), which, in relevant part, makes it "unlawful for any person . . . who has been convicted in any court of a crime punishable by imprisonment for a term exceeding one year" to "possess in or affecting commerce, any firearm or ammunition." At trial, the government presented testimony from Officer Joseph A. Caruthers of the Philadelphia Police Firearms Identification Unit. Officer Caruthers testified that the firearm confiscated from Gateward, an Astro .380 semi-automatic handgun, had been manufactured in Spain and imported by a Virginia distributor. See App. at 31a. In addition, Gateward stipulated that available testimony from an agent of the Bureau of Alcohol, Tobacco and Firearms would establish that the firearm had been shipped or transported in interstate commerce. See App. at 39a-40a. Gateward also stipulated that he had before been convicted of a felony. See App. at 40a.

A jury found Gateward guilty, and the district court sentenced him to 235 months imprisonment, 5 years supervised release, and a $50 special assessment. Gateward now appeals from his judgment of conviction, arguing that the felon firearm statute on which it is based is unconstitutional.

II.

Gateward's constitutional argument consists wholly of reference to the Supreme Court's recent decision in United States v. Lopez, 115 S.Ct. 1624 (1995). There the Court held invalid the Gun-Free School Zones Act, 18 U.S.C. §(s) 922(q), which prohibited firearm possession on school grounds or within 1000 feet thereof, as beyond Congress' commerce power, declaring that "[t]he Act neither regulates a commercial activity nor contains a requirement that the possession be connected in any way to interstate commerce." 115 S.Ct. at 1626. Gateward would have us view Section(s) 922(g) as the Lopez Court did Section(s) 922(q) — as essentially noncommercial, without the requisite nexus with interstate commerce, and accordingly unconstitutional.

We note initially that Gateward's constitutional challenge is raised for the first time on appeal, and would therefore ordinarily be reviewable only for plain error. See United States v. $184,505.01 in U.S. Currency, 72 F.3d 1160, 1165 n. 12 (3d Cir. 1995). However, the Lopez decision on which Gateward's claim depends was issued only after he was found guilty (though before judgment was entered). Under these circumstances, we move directly to the substantive question presented.

The Supreme Court has twice addressed the interstate commerce aspect of 18 U.S.C. App. Section(s) 1202(a), predecessor statute to Section(s) 922(g)(1), which made any felon "who receives, possesses, or transports in commerce or affecting commerce . . . any firearm" guilty of a federal offense. 18 U.S.C. App. Section(s) 1202(a) (repealed 1986).

In United States v. Bass, 404 U.S. 336 (1971), the defendant had been convicted under Section(s) 1202(a) for possessing a firearm, even though the government had made no attempt to show that the gun had been possessed "in commerce or affecting commerce." That was because the government read the statutory phrase "in commerce or affecting commerce" as applying only to "transports" and not to "receives" or "possesses." The Supreme Court disagreed, concluding that the phrase modified the words "receives" and "possesses" as well.

The Court found the statutory language ambiguous, but settled on this narrower reading because "unless Congress conveys its purpose clearly, it will not be deemed to have significantly changed the federal-state balance." 404 U.S. at 349. By applying the jurisdictional element to possessions and receipts, as well as transports, the Court avoided the question of the statute's constitutionality under the Commerce Clause. See id. at 351 ("[C]onsistent with our regard for the sensitive relation between federal and state criminal jurisdiction, our reading preserves as an element of all the offenses a requirement suited to federal criminal jurisdiction alone."); see also Lopez, 115 S.Ct. at 1631.

Six years later, in Scarborough v. United States, 431 U.S. 563 (1977), the Supreme Court established that proof that the possessed firearm had previously traveled in interstate commerce was sufficient to satisfy the statute's "in commerce or affecting commerce" nexus requirement.

We do not understand Lopez to undercut the Bass/Scarborough proposition that the jurisdictional element "in or affecting commerce" keeps the felon firearm law well inside the constitutional fringes of the Commerce Clause. The Lopez Court invalidated Section(s) 922(q) because "by its terms [it] has nothing to do with 'commerce' or any sort of economic enterprise, however broadly one might define those terms," and because "Section(s) 922(q) contains no jurisdictional element which would ensure, through case-by-case inquiry, that the firearm possession in question affects interstate commerce." 115 S.Ct. at 1630-31.

By contrast, Congress drafted Section(s) 922(g) to include a jurisdictional element, one which requires a defendant felon to have possessed a firearm "in or affecting commerce." If anything, the Court's opinion in Lopez highlights that crucial difference, and buttresses the validity of the felon firearm statute. See Lopez, 115 S.Ct. at 1631 (contrasting Section(s) 922(q)'s lack of a jurisdictional element with Section(s) 1202(a)'s nexus in Bass between firearm possession and commerce).

In United States v. Bishop, 66 F.3d 569 (3d Cir.) cert. denied, 116 S.Ct. 681 (1995), this court upheld 18 U.S.C. §(s) 2119, the federal anti-carjacking statute, against a post-Lopez Commerce Clause challenge. Noting that "section 2119 is limited to cars that have traveled in interstate or foreign commerce," we observed that "the Supreme Court's decisions in Bass and Scarborough compel the conclusion that the jurisdictional element in section 2119 provides a nexus sufficient to protect the statute from constitutional infirmity." Id. at 585.

We therefore join eight courts of appeals in upholding the constitutionality of Section(s) 922(g)(1) as a valid exercise of the commerce power. See United States v. Bradford, 78 F.3d 1216, 1222-23 (7th Cir. 1996); United States v. McAllister, 77 F.3d 387, 389-90 (11th Cir. 1996); United States v. Bates, 77 F.3d 1101, 1103-04 (8th Cir. 1996); United States v. Turner, 77 F.3d 887, 889 (6th Cir. 1996); United States v. Sorrentino, 72 F.3d 294, 296-97 (2d Cir. 1995); United States v. Hinton, No. 95-5095, 1995 WL 623876, at **2 (4th Cir. Oct. 25, 1995) (unpublished), cert. denied, 116 S.Ct. 1026 (1996); United States v. Bolton, 68 F.3d 396, 400 (10th Cir.), cert. denied, 116 S.Ct. 966 (1995); United States v. Collins, 61 F.3d 1379, 1383-84 (9th Cir.), cert. denied, 116 S.Ct. 543 (1995).

Gateward also argues that the indictment charging him with violation of Section(s) 922(g) contained no reference to possession of the firearm having been "in or affecting commerce." He is mistaken. The two-sentence indictment charges him with having "knowingly possessed in and affecting commerce, a firearm."Gateward last contends that "there was no attempt by the Government to show that the firearm had been possessed in or affecting commerce." Brief of Appellant at 13. Again, he is incorrect. The prosecution produced testimony that the firearm seized from Gateward had moved in interstate commerce, and Gateward stipulated to additional testimony establishing that fact. Gateward has failed to show that Bass and Scarborough are inapplicable here. We are satisfied that the government has shown the required link to commerce by both proof introduced at trial and the stipulation, which may account for Gateward's earlier failure to dispute it. See Trial Transcript, Mar. 15, 1995, at 197 (Closing Argument). Accordingly, we find no merit in Gateward's arguments.

III.

For the reasons set forth above, we will affirm the district court's judgment of conviction.


Summaries of

U.S. v. Gateward

United States Court of Appeals, Third Circuit
May 24, 1996
84 F.3d 670 (3d Cir. 1996)

holding the interstate commerce nexus of § 922(g) is established through proof the subject firearm had previously traveled in interstate commerce

Summary of this case from U.S. v. Blackman

holding that Section 922(g) does not violate the Commerce Clause because it was drafted to include a jurisdictional element

Summary of this case from United States v. Hauck

upholding federal statute barring felons from possessing firearms

Summary of this case from U.S. v. Spinello

upholding a § 922(g) conviction on the grounds that the prosecution had established that the firearm "had moved in interstate commerce"

Summary of this case from U.S. v. Torres

upholding federal statute barring felons from possessing firearms

Summary of this case from U.S. v. Spinello

affirming felon-inpossession statute, 18 U.S.C. § 922(g)

Summary of this case from CONGREGATION KOL AMI v. ABINGTON TOWNSHIP

In United States v. Gateward, 84 F.3d 670 (3d Cir. 1996), we upheld "the constitutionality of § 922(g)(1) as a valid exercise of the commerce power," id. at 672, and in United States v. Singletary, 268 F.3d 196 (3d Cir. 2001), we "reaffirm[ed] our holding in Gateward," and ruled that "proof... that the gun had traveled in interstate commerce, at some time in the past, was sufficient to satisfy the interstate commerce element."

Summary of this case from U.S. v. Allen

In Gateward, the Third Circuit distinguished Lopez by holding that § 922(g) does contain a jurisdictional element, explicitly limiting its application to situations in which the gun in question in some way concerns interstate commerce.

Summary of this case from United States v. Pierce

In Gateward, our appellate court held that § 922(g) is a proper exercise of Congressional power so long as it is proven that at some point before the defendant's possession, the firearm has traveled in interstate or foreign commerce.

Summary of this case from U.S. v. Ervin

In Gateward, our appellate court held that § 922(g) is a proper exercise of Congressional power so long as it is proven that at some point before the defendant's possession, the firearm has traveled in interstate or foreign commerce.

Summary of this case from U.S. v. Gilbert

In Gateward, the court held thatLopez did not change the implications of the Scarborough ruling, and that § 922(g) is a proper exercise of Congressional power so long as it is proven that at some point before the defendant's possession, the firearm has traveled in interstate or foreign commerce.

Summary of this case from Melendez v. U.S.

In Gateward, the Third Circuit upheld § 922(g)(1) by relying heavily on two Supreme Court cases that addressed the interstate commerce aspect of 18 U.S.C. § 1202(a), the predecessor statute to § 922(g)(1), which made any felon "who receives, possesses, or transports in commerce... any firearm" guilty of a federal offense.

Summary of this case from U.S. v. Dejesus
Case details for

U.S. v. Gateward

Case Details

Full title:UNITED STATES OF AMERICA v. KENNETH GATEWARD, A/K/A KENNETH CARR, APPELLANT

Court:United States Court of Appeals, Third Circuit

Date published: May 24, 1996

Citations

84 F.3d 670 (3d Cir. 1996)

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