Criminal: Defendant’s attack on 63-month sentence fails

Where the district court adequately explained why it sentenced a man who pleaded guilty to possession of a firearm and ammunition by a convicted felon to 63 months’ imprisonment, the sentence was affirmed.

Background

Antwaun O. Heaggeans pleaded guilty to possession of a firearm and ammunition by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). The district court varied upward and sentenced Heaggeans to 63 months’ imprisonment.

Heaggeans asserts that § 922(g)(1) is facially unconstitutional and unconstitutional as applied to him following New York State Rifle & Pistol Ass’n v. Bruen, in which the Supreme Court held that a firearm regulation is valid under the Second Amendment only if it “is consistent with this Nation’s historical tradition of firearm regulation.” Heaggeans further argues that his sentence is procedurally unreasonable because the district court did not provide an adequate explanation for the imposed sentence.

Bruen

Two recent decisions foreclose Heaggeans’s Second Amendment challenges on appeal. In United States v. Canada, 123 F.4th 159 (4th Cir. 2024), this court considered and rejected a constitutional challenge to § 922(g)(1), holding that “[s]ection 922(g)(1) is facially constitutional because it has a plainly legitimate sweep and may constitutionally be applied in at least some set of circumstances.” Likewise, in United States v. Hunt, 123 F.4th 697 (4th Cir. 2024), the court affirmed “the Supreme Court’s repeated instruction that longstanding prohibitions on the possession of firearms by felons . . . are presumptively lawful.”

Sentencing

“A district court is required to provide an individualized assessment based on the facts before the court, and to explain adequately the sentence imposed to allow for meaningful appellate review and to promote the perception of fair sentencing.” “As part of this individualized assessment, the district court must address or consider all non-frivolous reasons presented for imposing a different sentence and explain why it has rejected those arguments.”

Heaggeans focuses on the brief statement the district court made prior to sentencing Heaggeans to argue that the court did not adequately explain its reasoning for the chosen sentence. However, “it is . . . well established that our review of a district court’s sentencing explanation is not limited to the court’s statements at the moment it imposes sentence.”

Here, the court explicitly considered the § 3553(a) factors over the course of the sentencing and gave an individualized assessment of Heaggeans by considering the specific circumstances regarding the instant conflict with law enforcement and Heaggeans’s history of violence towards law enforcement. The court also considered Heaggeans’s mental health and difficult life circumstances but found that these circumstances did not mitigate the violent nature of the offense and Heaggeans’s criminal history.

The court again considered Heaggeans’s mental health in recommending that Heaggeans receive mental health treatment while incarcerated and on supervised release, noting that Heaggeans had the capacity to become a good citizen. The district court thus adequately explained its chosen sentence and Heaggeans’s sentence is procedurally reasonable.

Affirmed.

United States v. Heaggeans, Case No. 25-4141, Nov. 4, 2025. 4th Cir. (per curiam), from EDVA at Richmond (Payne). Geremy C. Kamens, Patrick L. Bryant and Amy L. Austin for Appellant. Eric S. Siebert and Ellen H. Theisen for Appellee. VLW 025-2-406. 4 pp.