United States v. Leopaul
Leopaul
Court
Unknown Court
Decided
June 17, 2025
Importance
35%
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Case Summary
Case: 24-30697 Document: 51-1 Page: 1 Date Filed: 06/17/2025 United States Court of Appeals for the Fifth Circuit ____________ United States Court of Appeals Fifth Circuit FILED No. 24-30697 June 17, 2025 Summary Calendar ____________ Lyle W. Cayce Clerk United States of America, Plaintiff—Appellee, versus Frank Deonta Leopaul, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Western District of Louisiana USDC No. 6:24-CR-22-1 ______________________________ Before King, Southwick, and Engelhardt, Circuit Judges. Per Curiam: * Frank Deonta Leopaul appeals following his conviction for possession of a firearm and ammunition after having previously been convicted of a felony, in violation of 18 U.S.C. § 922(g)(1). He argues that § 922(g)(1) is unconstitutional on its face in light of New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). Leopaul concedes that the argument is _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 24-30697 Document: 51-1 Page: 2 Date Filed: 06/17/2025 No. 24-30697 foreclosed by 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), but he wishes to preserve it for further review. The Government has moved without opposition for summary affirmance or, alternatively, for an extension of time to file its brief. As the Government asserts and as Leopaul concedes, the sole issue raised on appeal is foreclosed by Diaz. See id.; see also United States v. Contreras, 125 F.4th 725, 729 (5th Cir. 2025). Therefore, summary affirmance is appropriate. See Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). Accordingly, the motion for summary affirmance is GRANTED, the alternative motion for an extension of time is DENIED, and the judgment of the district court is AFFIRMED. 2
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Date Decided
June 17, 2025
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Case Summary
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Case Overview
The case United States v. Frank Deonta Leopaul was decided by the United States Court of Appeals for the Fifth Circuit on June 17, 2025. Leopaul appealed his conviction for possession of a firearm and ammunition after being previously convicted of a felony, in violation of 18 U.S.C. § 922(g)(1). The appeal primarily challenged the constitutionality of the statute in light of the landmark case New York State Rifle & Pistol Ass’n, Inc. v. Bruen.
Key Legal Issues
- Constitutionality of 18 U.S.C. § 922(g)(1): Leopaul argued that the statute is unconstitutional based on the precedent set in Bruen.
- Foreclosure by Precedent: Leopaul acknowledged that his argument was foreclosed by the Fifth Circuit's decision in United States v. Diaz.
Court's Decision
The Fifth Circuit affirmed the judgment of the district court, granting the Government's motion for summary affirmance. The court found that the arguments presented by Leopaul were already addressed in prior rulings, specifically in Diaz and United States v. Contreras.
Legal Reasoning
The court's decision was based on the following reasoning:
- Precedent: The court emphasized that Leopaul's constitutional argument regarding § 922(g)(1) was already settled in Diaz, which held that the statute remains constitutional post-Bruen.
- Summary Affirmance: The court determined that summary affirmance was appropriate given the clear precedent and lack of opposition from Leopaul regarding the Government's motion.
Key Holdings
- The court upheld Leopaul's conviction for possession of a firearm and ammunition under 18 U.S.C. § 922(g)(1).
- The court granted the Government's motion for summary affirmance, reinforcing the precedent established in Diaz.
Precedents and Citations
- New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022)
- United States v. Diaz, 116 F.4th 458 (5th Cir. 2024)
- United States v. Contreras, 125 F.4th 725 (5th Cir. 2025)
- Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969)
Practical Implications
The ruling in United States v. Leopaul reinforces the constitutionality of federal firearm possession laws for individuals with prior felony convictions. The decision highlights the importance of adhering to established precedents in appellate courts, particularly in the context of Second Amendment rights. Legal practitioners should note the implications of this ruling in future cases involving firearm possession and constitutional challenges. Additionally, the case serves as a reminder of the evolving landscape of gun rights litigation in the United States, particularly in light of recent Supreme Court decisions.
This case underscores the necessity for defendants to consider existing precedents when formulating constitutional arguments, as courts may be reluctant to entertain claims that have already been resolved.
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Status
Decided
Date Decided
June 17, 2025
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