Supreme Court Report

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Marcus Albert Rambo v. United States

IFP petition · United States Court of Appeals for the Eleventh Circuit, No. 23-13772 · judgment October 20, 2025


Certiorari denied · February 23, 2026

Questions presented

  1. Whether after New York State Rifle & Pistol Association v. Bruen, 597 U.S. 1 (2022) and United States v. Rahimi, 602 U.S. 680 (2024), a criminal defendant may raise an as-applied Second Amendment challenge to 18 U.S.C. § 922(g)(1).

  2. If so, whether under the Bruen/Rahimi methodology, the Second Amendment is unconstitutional as applied to a defendant like Petitioner with only non-violent priors.

Counsel of record

For petitioner
Brenda Greenberg Bryn
Federal Public Defender

For respondent
D. John Sauer
Solicitor General

Case

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, February 23, 2026 · Certiorari denied

Proceedings

  1. Feb 23 2026
    Petition DENIED.
  2. Jan 29 2026
    DISTRIBUTED for Conference of 2/20/2026.
  3. Jan 26 2026
    Waiver of right of respondent United States to respond filed.
  4. Jan 16 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due February 23, 2026)