Edward Junior Gibbs v. State of Florida

No. 3D23-1676 · Florida Third District Court of Appeal · October 8, 2025 · No. 3D23-1676

Summary

The Third District Court of Appeal of Florida affirmed Edward Junior Gibbs's conviction in a per curiam opinion. The court rejected a Second Amendment challenge to Florida's prohibition on firearm possession by convicted felons, relying on federal and Florida precedent upholding comparable restrictions.

Holdings

  1. Florida's prohibition on convicted felons possessing firearms survives Second Amendment scrutiny.
  2. United States v. Rahimi did not invalidate or materially undermine prohibitions on firearm possession by convicted felons.

Questions Presented

  1. Whether Florida's prohibition on possession of firearms by convicted felons, section 790.23(1)(a), Florida Statutes, violates the Second Amendment.
  2. Whether the United States Supreme Court's decision in United States v. Rahimi altered the constitutional analysis applicable to prohibitions on firearm possession by convicted felons.

Disposition

affirmed

Cases Cited (15)

  • United States v. Dubois, 139 F.4th 887 (11th Cir. 2025)(followed)
  • Vincent v. Bondi, 127 F.4th 1263 (10th Cir. 2025)(followed)
  • United States v. Young, No. 23-10464, 2024 WL 3466607, at *8 (11th Cir. July 19, 2024)(followed)
  • United States v. Hester, No. 23-11938, 2024 WL 4100901 (11th Cir. Sept. 6, 2024)(followed)
  • United States v. Langston, 110 F.4th 408, 420 (1st Cir. 2024)(followed)
  • United States v. Jackson, 110 F.4th 1120, 1125 (8th Cir. 2024)(followed)
  • United States v. Hunt, 123 F.4th 697, 708 (4th Cir. 2024)(followed)
  • United States v. Warner, 131 F.4th 1137, 1148 (10th Cir. 2025)(followed)
  • Range v. Att'y Gen. United States, 124 F.4th 218, 232 (3d Cir. 2024)(distinguished)
  • United States v. Williams, No. 24-1244, 2025 WL 1089531, at *2 (6th Cir. Apr. 11, 2025)(followed)

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Cited In (0)

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