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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The CCWL. Gives you a few options versus the state open carry laws, it shows you took an approved gun class, and you have a certificate showing that ( required for the concealed carry weapons license ) the 2nd is you can purchase your firearm and receive It the same day, while others have a 5 day waiting period, per Florida law…..the 3rd is if you get in a situation you were trained for, the CCWL license goes over better with law enforcement if they are called if you had to defend yourself, with or without the CCWL , open carry in Florida is the law.
I agree…but we are in a different situation here. Imagine I get yourself in a situation where I have to pull a gun…well, if I pull the gun, is not for an static display. Then, the cops arrives and for my luck, I get a rookie cop. I give my license and the cop sees the scarlet letters in my license. The rookie cop then decides to arrest me in the spot because he only sees the scarlet letters and have no basic fundamental understanding of the types of adjudication and why I am a registrant but not a felon. Then I have to switch my brain from victim of the events to have to find a way to educate this rookie cop as of why he needs to take the shackles off my wrists. Just imagine that. This is a hypothetical scenario I play in my mind all the times and why I am very careful because the threat to me and my family is a real thing everyday of my life. Now the open carry law to me, is a big mistake, but that is my opinion as one of the members stated, “The guys who should have a firearm are the ones committing gun crimes”. Which is true, and those folks feel empowered and shielded by the law. Whatever the case is, be careful, know the laws and abide to the laws, at all times….at all times !!
Sadly, those who really shouldn’t have a firearm are the very ones committing new gun-related crimes. The law of prohibition doesn’t stop them because they don’t respect the law in the first place.
That means you can vote, have a gun, and do what everyone else does,except have to register every 3 months…..
Yeap…the damn registration…. I hope one day….it will go away….let me sing this song….”Rain Rain don’t you stay, make the registration go away” ! LOL ….
So if I am a registered citizen, 6 years off of probation, but not a felon, what does this mean for me?
If you don’t have a formal conviction in which you can legally state that you are not a felon, then you can simply apply for a CCWL. I would advise NOT to purchase, although in Florida now you can, but I wouldn’t advise you to purchase any firearm until you get your CCWL. That is the best way to show that you can legally purchase and and own a firearm and won’t be questioned. Anytime you buy one, provide your CCWL. Carry it with you all the time. Don’t EVER buy anything from your buddies, friends, or anything else that is not an FFL, established armories or licensed FFL Pawn shops. There will be a background check for the CCWL, and when buying a firearm, and in many instances, our background check takes a lot longer that a regular person ( and believe me, someone always say “I don’t know why it takes this long with this background check”)….well you know why but you won’t say anything… ., but, it always gets approved anyways. You will not be able to obtain a PIN from ATF, because the way they see it, if you later on commit a crime in which you declare guilty and subsequently becomes a Felon, they know you will lose your CCWL and the right to own and possess a firearm. So in other words, lay low, don’t be flashy, and don’t be cocky with it. The less is better. Learn what are your legalities and what are the don’ts.
Thank God that I don’t have a formal conviction. I retained by rights and I have my CCWL. So, if there is an intrepid, or someone who has the urge or desire to put my family under threat, or wants to cause harm to my house or the people under my roof….. well….there will be serious consequences. I sure hope that the Supreme Court settles this issue in our favor….
My rights are from God not government.