UNITED STATES OF AMERICA v. JERMAINE BROWN - Articles

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Posted by: Azya Thornton on Aug 14, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Needum L. Germany, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Memphis, Tennessee, for Appellant

Attorneys 2: ON BRIEF: Mary H. Morris, Gregory A. Wagner, UNITED STATES ATTORNEY’S OFFICE, Memphis, Tennessee, for Appellee.

Judge(s): MOORE, GRIFFIN, and NALBANDIAN, Circuit Judges

Court Appealed: United States District Court for the Western District of Tennessee at Memphis

KAREN NELSON MOORE, Circuit Judge. Defendant-appellant Jermaine Brown brings an as-applied Second Amendment challenge to the constitutionality of his conviction for violating 18 U.S.C. § 922(o), which prohibits the transfer or possession of machineguns. As a matter of circuit law, the Second Amendment does not protect a right to possess machineguns. Accordingly, we AFFIRM Brown’s conviction.

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