United States v. George Richardson
CourtCourt of Appeals for the Eighth Circuit
Date FiledMay 18, 2026
Docket25-2251, 25-2260
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
United States Court of Appeals
For the Eighth Circuit
___________________________
No. 25-2251
___________________________
United States of America
Plaintiff - Appellee
v.
George A. Richardson
Defendant - Appellant
___________________________
No. 25-2260
___________________________
United States of America
Plaintiff - Appellee
v.
Aaron F. Pepple
Defendant - Appellant
____________
Appeals from United States District Court
for the Western District of Missouri - Kansas City
____________
Submitted: April 17, 2026
Filed: May 18, 2026
[Published]
____________
Before KELLY, GRASZ, and KOBES, Circuit Judges.
____________
PER CURIAM.
Aaron Pepple and George Richardson were each indicted on one count of
being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and
924(a)(8). Each moved to dismiss the indictment, arguing that § 922(g)(1) is
unconstitutional on its face and as applied to him. The district court 1 denied the
motions, and both pleaded guilty, reserving the right to appeal those rulings.
First, Pepple and Richardson ask us to hold that § 922(g)(1) is unconstitutional
on its face because it categorically bans all felons from possessing firearms.
Alternatively, they argue that § 922(g)(1) is subject to as-applied Second
Amendment challenges based on individual circumstances, including
dangerousness. These arguments are squarely foreclosed by precedent. United States
v. Jackson, 110 F.4th 1120, 1125–29 (8th Cir. 2024), cert. denied, 145 S. Ct. 2708
(2025) (holding “Congress acted within the historical tradition when it enacted
§ 922(g)(1) and the prohibition on possession of firearms by felons,” and “there is
no need for felony-by-felony litigation regarding the constitutionality of
§ 922(g)(1)”); United States v. Cunningham, 114 F.4th 671, 675 (8th Cir. 2024)
(“The longstanding prohibition on possession of firearms by felons is
constitutional[.]”). Pepple and Richardson assert these decisions were wrongly
decided, but “[i]t is a cardinal rule in our circuit that one panel is bound by the
1
The Honorable Howard F. Sachs, United States District Judge for the
Western District of Missouri, adopting the report and recommendation of the
Honorable Jill A. Morris, United States Magistrate Judge for the Western District of
Missouri.
-2-
decision of a prior panel.” United States v. Ledvina, 166 F.4th 716, 720 (8th Cir.
2026) (quoting Mader v. United States, 654 F.3d 794, 800 (8th Cir. 2011) (en banc)).
Next, Pepple and Richardson argue § 922(g)(1) is unconstitutional because it
is overbroad. As they acknowledge, an overbreadth challenge is a type of facial
challenge traditionally restricted to the First Amendment context. See, e.g., United
States v. Hansen, 599 U.S. 762, 769–70 (2023). However, even assuming the
overbreadth doctrine applies in the Second Amendment context, an overbreadth
challenge can only succeed where “a law’s unconstitutional applications . . . [are]
substantially disproportionate to the statute’s lawful sweep.” Id. at 770 (citations
omitted). As discussed, we have held that § 922(g)(1) is constitutional in all its
applications. Jackson, 110 F.4th at 1125–29; Cunningham, 114 F.4th at 675; Browne
v. Reynolds, 150 F.4th 975, 979 (8th Cir. 2025) (“[T]he federal prohibition on
possession of firearms by felons is constitutional as a categorical matter.”). Thus,
their overbreadth argument is also foreclosed by precedent. See Ledvina, 166 F.4th
at 720 (quoting Mader, 654 F.3d at 800).
We affirm.
______________________________
-3-