United States v. Ibarra
Ibarra
Court
Fifth Circuit Court of Appeals
Decided
June 10, 2025
Jurisdiction
F
Importance
48%
Practice Areas
Case Summary
Case: 24-50910 Document: 54-1 Page: 1 Date Filed: 06/10/2025 United States Court of Appeals for the Fifth Circuit United States Court of Appeals ____________ Fifth Circuit FILED No. 24-50910 June 10, 2025 Summary Calendar Lyle W. Cayce ____________ Clerk United States of America, Plaintiff—Appellee, versus Cristobal Ibarra, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Western District of Texas USDC No. 5:24-CR-27-1 ______________________________ Before Wiener, Ho, and Ramirez, Circuit Judges. Per Curiam: * Cristobal Ibarra appeals his guilty plea conviction for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). At the time he committed the § 922(g)(1) offense of which he was convicted, Ibarra had multiple prior felony convictions, including a 2014 Arizona conviction for aggravated assault and a 2018 conviction for misconduct involving weapons. _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 24-50910 Document: 54-1 Page: 2 Date Filed: 06/10/2025 No. 24-50910 Ibarra argues that § 922(g)(1) exceeds Congress’s authority under the Commerce Clause and violates the Second Amendment, both facially and as applied to him, in light of the test set forth in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). The Government has filed an opposed motion for summary affirmance or, in the alternative, an extension of time to file a merits brief. Summary affirmance is appropriate if “the position of one of the parties is clearly right as a matter of law so that there can be no substantial question as to the outcome of the case.” United States v. Holy Land Found. For Relief & Dev., 445 F. 3d 771, 781 (5th Cir. 2006) (quoting Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969)). The Government is correct that Ibarra’s constitutional challenges are foreclosed. See United States v. Diaz, 116 F.4th 458, 471-72 (5th Cir. 2024), petition for cert. filed (U.S. Feb. 18, 2025) (No. 24-6625); United States v. Bullock, 123 F.4th 183, 185 (5th Cir. 2024); United States v. Traxler, 764 F.3d 486, 489 (5th Cir. 2014); United States v. Alcantar, 733 F.3d 143, 145-46 (5th Cir. 2013); see also United States v. Schnur, 132 F.4th 863, 867-70 (5th Cir. 2025). Because Diaz, Bullock, Traxler, and Alcantar are clearly dispositive, we affirm the district court’s judgment without further briefing. See United States v. Bailey, 924 F.3d 1289, 1290 (5th Cir. 2019). The motion for summary affirmance is GRANTED, the alternative motion for an extension of time is DENIED as moot, and the judgment of the district court is AFFIRMED. 2
Case Details
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Status
Decided
Date Decided
June 10, 2025
Jurisdiction
F
Court Type
appellate
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Case Overview
Case Name: United States v. Ibarra
Citation: Unknown
Court: Court of Appeals for the Fifth Circuit
Date: June 10, 2025
Jurisdiction: Federal
In the case of United States v. Ibarra, the Fifth Circuit Court of Appeals addressed the appeal of Cristobal Ibarra, who challenged his conviction for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Ibarra's appeal raised significant constitutional questions regarding the scope of federal authority under the Commerce Clause and the Second Amendment.
Key Legal Issues
Ibarra's appeal focused on two primary legal issues:
- Constitutionality of 18 U.S.C. § 922(g)(1): Ibarra argued that the statute exceeded Congress’s authority under the Commerce Clause.
- Second Amendment Rights: He contended that the statute violated his Second Amendment rights, both facially and as applied to his case, referencing the precedent set in New York State Rifle & Pistol Ass’n, Inc. v. Bruen.
Court's Decision
The Fifth Circuit affirmed the district court's judgment without further briefing, granting the government's motion for summary affirmance. The court concluded that Ibarra's constitutional challenges were foreclosed by established precedent, thereby upholding his conviction.
Legal Reasoning
The court's decision relied heavily on previous rulings that affirmed the constitutionality of 18 U.S.C. § 922(g)(1), particularly in light of recent case law. The judges noted that:
- The Commerce Clause grants Congress the authority to regulate firearm possession by felons.
- The Second Amendment does not provide an absolute right for felons to possess firearms, especially in the context of federal regulations.
Key Holdings
- The Fifth Circuit found that Ibarra's arguments against the constitutionality of § 922(g)(1) were not persuasive and were already addressed in prior cases.
- The court cited multiple precedents, including United States v. Diaz and United States v. Bullock, affirming the legality of the statute as applied to felons.
Precedents and Citations
The court referenced several key cases that influenced its decision, including:
- United States v. Diaz, 116 F.4th 458 (5th Cir. 2024)
- United States v. Bullock, 123 F.4th 183 (5th Cir. 2024)
- United States v. Traxler, 764 F.3d 486 (5th Cir. 2014)
- United States v. Alcantar, 733 F.3d 143 (5th Cir. 2013)
- United States v. Schnur, 132 F.4th 863 (5th Cir. 2025)
These cases collectively supported the court's conclusion that Ibarra's constitutional challenges were without merit.
Practical Implications
The ruling in United States v. Ibarra reinforces the legal framework surrounding firearm possession by felons, clarifying that:
- Felons remain prohibited from possessing firearms under federal law, regardless of their arguments regarding the Second Amendment.
- The decision may deter similar appeals from individuals seeking to challenge their convictions based on constitutional grounds.
- Legal practitioners should note the court's reliance on established precedents, which may limit the scope of future challenges to § 922(g)(1).
This case serves as a significant reminder of the boundaries of Second Amendment rights in the context of federal regulations and the ongoing interpretation of the Commerce Clause in relation to firearm possession laws.
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Case Details
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Status
Decided
Date Decided
June 10, 2025
Jurisdiction
F
Court Type
appellate
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Additional information
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