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Patrick Tate Adamiak v. United States

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 23-4451 · judgment October 14, 2025


Certiorari denied · May 18, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Whether an indictment satisfies the Fifth and Sixth Amendments when it charges possession of a “machinegun” or “destructive device” under 26 U.S.C. §§ 5845 and 5861(d) when the indictment does not allege the facts necessary to bring these items within the statutory definition of the crime.

  2. Whether a court may uphold an invalid indictment on the ground that the defendant could have sought a bill of particulars, notwithstanding this Court’s settled rule that a bill of particulars cannot save an invalid indictment.

  3. Whether the Fourth Circuit erred in summarily dismissing Petitioner’s as-applied Second Amendment challenge based on nothing more than erroneous circuit precedent and on which there are multiple circuit splits of authority on questions presently before this Court.

Counsel of record

For petitioner
Mark William Pennak
Maryland Shall Issue, Inc.

For respondent
D. John Sauer
Solicitor General

Case

Conference history
Distributed for 1 conference

Amicus briefs
2 cert-stage

Linked docket
25A888

Proceedings

  1. May 18 2026
    Petition DENIED.
  2. May 11 2026
    Brief amici curiae of The National Association for Gun Rights, et al. filed. (Distributed)
  3. May 04 2026
    Brief amici curiae of Second Amendment Foundation, et al. filed. (Distributed)
  4. Apr 28 2026
    DISTRIBUTED for Conference of 5/14/2026.
  5. Apr 23 2026
    Waiver of right of respondent United States to respond filed.
  6. Apr 10 2026
    Petition for a writ of certiorari filed. (Response due May 18, 2026)
  7. Mar 06 2026
    Application (25A888) granted by The Chief Justice extending the time to file until April 10, 2026.
  8. Mar 02 2026
    Application (25A888) to extend further the time from March 12, 2026 to April 10, 2026, submitted to The Chief Justice.
  9. Feb 11 2026
    Application (25A888) granted by The Chief Justice extending the time to file until March 12, 2026.
  10. Feb 01 2026
    Application (25A888) to extend the time to file a petition for a writ of certiorari from February 10, 2026 to March 12, 2026, submitted to The Chief Justice.