Dru Stevenson, Professor of Law

The Seventh Circuit issued three Second Amendment decisions on April 2, all involving the federal felon‑in‑possession statute, 18 U.S.C. § 922(g)(1). The most notable is United States v. Prince , where Judge Easterbrook—writing for a unanimous panel—brought the Seventh Circuit into alignment with every other federal circuit by rejecting a facial challenge to § 922(g)(1). The court emphasized that the statute has many unquestionably constitutional applications, which is enough to defeat a facial attack under standard principles of constitutional adjudication. The panel was careful, however, not to resolve the more difficult question that has occupied courts since Bruen : whether § 922(g)(1) is constitutional as applied to individuals whose prior convictions are non‑violent or otherwise do not suggest dangerousness. That issue remains open in the Seventh Circuit. A companion case, United States v. Watson , illustrates the court’s incremental approach. Chief Judge Brennan upheld § 92...