The United States Court of Appeals for the Second Circuit has upheld the conviction of Nick Laguna for possession of a firearm as a convicted felon. The court's decision, delivered on October 27, 2026, affirms a lower court's ruling that sentenced Laguna to 46 months in prison, followed by three years of supervised release. This ruling is significant as it reinforces the legal framework surrounding firearm possession for individuals with felony convictions.

Laguna's case stems from a guilty plea he entered in September 2024, where he admitted to possessing a firearm in violation of 18 U.S.C. § 922(g)(1). This statute prohibits individuals with felony convictions from owning firearms. The court's ruling not only impacts Laguna but also sets a precedent for similar cases involving firearm possession by convicted felons.

Background

Nick Laguna was convicted in the United States District Court for the Southern District of New York. The judge overseeing the case was Jennifer H. Rearden. Laguna's conviction arose from a guilty plea related to his possession of a firearm, which he argued should be vacated based on the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). This case raised questions about the constitutionality of firearm possession laws for individuals with felony convictions.

Laguna's legal team, led by attorney Daniel Habib from the Federal Defenders of New York, argued that his conviction was unconstitutional as applied to his situation. They contended that the ruling in Bruen should invalidate his conviction. However, the government, represented by Assistant U.S. Attorney Diarra M. Guthrie, maintained that the law was constitutional, citing precedents that supported the conviction.

The Ruling

The Second Circuit Court ultimately affirmed the lower court's judgment, stating, "Laguna's conviction for possessing a firearm as a convicted felon in violation of § 922(g)(1) is upheld." The court emphasized that the argument for vacating the conviction was reviewed for plain error, as Laguna had not raised it during the initial proceedings. The court referenced its earlier ruling in Zherka v. Bondi, which upheld the constitutionality of § 922(g)(1) even for individuals with nonviolent felony convictions.

The court further explained that the reasoning applied in Zherka was relevant to Laguna’s case, as he had a violent felony conviction. The ruling noted, "Because Zherka applies a fortiori to firearm dispossession following a violent predicate crime of conviction like Laguna’s, we affirm Laguna’s conviction." This statement underscores the court's stance that the law remains valid and applicable to individuals with violent felony backgrounds.

In addition to affirming the conviction, the court also addressed the conditions of Laguna's supervised release. The District Court had imposed a special condition requiring Laguna to submit his electronic devices to searches by probation officers if there was reasonable suspicion of a violation. The Second Circuit found that the District Court had not abused its discretion in imposing this condition.

Impact

This ruling is significant for several reasons. It reinforces the legal principle that individuals with felony convictions, particularly those with violent offenses, can be prohibited from possessing firearms. The court's reliance on previous rulings establishes a clear framework for future cases involving firearm possession and the rights of convicted felons.

Moreover, the ruling regarding supervised release conditions highlights the court's willingness to impose stringent measures for individuals with extensive criminal histories. The court noted that Laguna had a long history of criminal conduct, which justified the electronic search condition as a means of protecting the community and ensuring compliance with the terms of his release.

What's Next

Laguna's legal team has the option to appeal the ruling to the U.S. Supreme Court, but it is unclear whether they will pursue this route. There are no related cases pending that directly connect to this ruling, but the implications of the court's decision may influence future legal arguments surrounding firearm possession laws for convicted felons.