The Third Circuit Court of Appeals has upheld the conviction of Darryl Craig for possession of ammunition by a convicted felon. This decision, filed on October 22, 2026, confirms that Craig's conviction remains valid despite his argument that the law under which he was convicted is unconstitutional. The ruling is significant as it clarifies the legal standing of 18 U.S.C. § 922(g)(1) following a recent Supreme Court decision.

Darryl Craig's case began when he pleaded guilty to possession of ammunition, a violation of federal law. This law prohibits individuals with felony convictions from possessing firearms or ammunition. Craig was sentenced to time served and three years of supervised release but later appealed his conviction, arguing that the statute was unconstitutional based on a recent Supreme Court ruling.

The Supreme Court case Craig referenced is United States v. Rahimi, which addressed the constitutionality of similar gun possession laws. Craig contended that under the Rahimi ruling, 18 U.S.C. § 922(g)(1) is facially unconstitutional, meaning that it should be invalidated in all circumstances. His appeal was heard by the Third Circuit after being initially decided in the U.S. District Court for the Western District of Pennsylvania.

The Ruling

The Third Circuit ruled against Craig, affirming his conviction. The court stated, “A facial challenge is the ‘most difficult challenge to mount successfully,’ because it requires a defendant to establish that no set of circumstances exists under which the [challenged statute] would be valid.” This means that for Craig's argument to succeed, he would need to prove that the law could not be constitutional in any situation.

The court also noted that the government only needed to show that the statute is constitutional in some applications. They referenced previous cases where similar challenges had been rejected, stating, “Our binding precedent forecloses Craig’s appeal.” This indicates that the court found Craig's argument insufficient to overturn established legal interpretations of the statute.

Impact

This ruling has significant implications for individuals with felony convictions who may seek to challenge their convictions under 18 U.S.C. § 922(g)(1). The Third Circuit's decision reinforces the constitutionality of this law, particularly in light of the Rahimi case. It suggests that challenges to this statute will likely face considerable hurdles in the future, especially if they are framed as facial challenges.

The decision also serves as a reminder of the importance of preserving legal arguments throughout the judicial process. The court noted that Craig had not raised an as-applied challenge—an argument that might have been more successful—during his initial proceedings. This forfeiture of argument highlights the critical nature of presenting all potential defenses in lower courts.

What's Next

Craig's options for appeal appear limited following this ruling. The court's decision is not binding precedent, as it is classified as a nonprecedential opinion. This means that while it is a significant ruling, it does not create a new legal standard that must be followed in future cases. Given the court's firm stance, it is unlikely that Craig will successfully appeal this decision further. Details on any related cases were not available in the court filing.