Firearm Possession by Registrants: What the 3rd Circuit Giveth, the 6th Circuit Taketh Away

Two weeks ago, some registrants had reason for cautious optimism about the Second Amendment. Three days later, a federal appeals court in another part of the country showed how fragile that optimism is.

On October 13, 2026, the full Third Circuit, sitting en banc, decided Williams v. Attorney General. As we reported in When Exposure Meets the Right to Self-Defense: What Williams Could Mean for Registrants, the court held that the federal felon-in-possession ban, 18 U.S.C. § 922(g)(1), could not constitutionally be applied to Edward Williams based on his repeat DUI conviction. The court made clear that a past conviction alone does not settle whether a person may be disarmed for life. The government must justify the restriction by reference to the nation’s historical tradition of firearm regulation, including whether the person poses a present threat of violence.

As we cautioned then, Williams did not decide the rights of registrants. But it offered a framework: courts should look past labels and ask whether the government has a historically grounded reason to disarm this particular person. For people whose names, addresses, and photos are published to the world, and who face real threats of vigilante violence, that question matters.

Three days later, the Sixth Circuit decided a case squarely about a registrant, United States v. Bloomfield. Bloomfield’s only prior conviction was a 2011 federal conviction for receipt of child pornography, for which he served 70 months, completed supervised release, and registered under SORNA. In 2023, deputies searched the house and found five firearms and ammunition in his bedroom. He was charged under § 922(g)(1), pleaded guilty while preserving his constitutional challenge, and received 20 months. On appeal, he argued the statute was unconstitutional as applied to him. The panel affirmed his conviction.

The Court found that possession of CSAM causes continuing harm to the children depicted, based its reading of the Supreme Court’s decision in Paroline v. United States, 572 U.S. 434, 449 (2014), the court said possessing child pornography causes “serious and continuing harm” to victims through the trauma of knowing images of their abuse are viewed again and again.

The most troubling holding is how the court treated registration itself. The district court found it “defies common sense” to warn the public (via registration) that someone is “dangerous” and then call him “not dangerous”.

Another troubling part of the decision is that Paroline was a restitution case. The Supreme Court used that language to explain why victims of child pornography suffer real, ongoing harm that defendants can be ordered to compensate. It did not address whether people convicted of possession are presently dangerous. The Sixth Circuit has now conflated “harm to the victim” with present dangerousness.

Bloomfield is unpublished, so it is not binding precedent even in the Sixth Circuit, though it shows how some judges see the issue. And neither decision binds Florida. Florida sits in the Eleventh Circuit, which has held that § 922(g)(1) is not open to as-applied challenges at all, and Florida’s own ban in § 790.23, Florida Statutes, applies independently. Our only hope is that the Supreme Court might take up the issue because there’s clearly a split among the circuits and this is an important matter because it concerns a fundamental right.


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7 thoughts on “Firearm Possession by Registrants: What the 3rd Circuit Giveth, the 6th Circuit Taketh Away”

  • October 30, 2026

    Apparently in the eyes of government there’s a fine line between privileges and rights. Driving is a privilege, possessing a firearm is a constitutional right. Shall not be infringed.

    Reply
    • October 30, 2026

      There are exceptions to constitutional rights. You can’t shout fire in a crowded theater.

      Reply
  • October 30, 2026

    I think about all the people who watch violent movies, YouTube videos of actual beheadings, murders, violence towards animals and this should concern everyone just as much. Where is the decision to find these people and take away their right to bear arms. After all this material is out there for everyone to see over and over again. What a crazy world we live in.

    Reply
  • October 30, 2026

    My adjudication was withheld, so not a convicted felon, but on the registry.

    Am I allowed to possess a firearm?

    Reply
    • October 30, 2026

      100% your not a felon

      Reply
    • October 30, 2026

      My current understanding is not anymore. I seem to recall that 25 or 30 years ago that was an issue because the federal system does not have with adjudication withheld. But things that I have seen more recently say that they have resolved that conflict in favor of you being consider considered, you have been convicted for purposes of federal firearms laws.

      Reply
    • October 30, 2026

      Yes you are, I’m also adjudicated and have weapons, all cleared by FDLE, when you purchase your firearm….. you have the rights of everybody else walking the street except you’re on the registry….. including the right to carry in Florida

      Reply

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