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.