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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

Question 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

Conference history
Distributed for 1 conference

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)