United States v. Squire

── United States v. Squire ── Court: Court of Appeals for the Fifth Circuit Date: June 02, 2026 Category: Direct Criminal Case: 25-30324 Document: 70-1 Page: 1 Date Filed: 06/02/2026 United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit ____________ FILED No. 25-30324 June 2, 2026 ____________ Lyle W. Cayce Clerk United States of America, Plaintiff—Appellee, versus Curtis Squire, Defendant—Appellant. ______________________________ Appeal from the United States District Court for the Eastern District of Louisiana USDC No. 2:24-CR-41-1 ______________________________ Before Clement, Southwick, and Engelhardt, Circuit Judges. Edith Brown Clement, Circuit Judge: This case presents a novel question about whether the Second Amendment protects a convicted drug trafficker from being dispossessed of a firearm inside his home based on our Nation’s historical tradition of firearm regulation. Curtis Squire was indicted for possession of a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Squire moved to dismiss the indictment, raising several constitutional challenges, including that § 922(g)(1) is unconstitutional as applied to him—regardless of his felon status—because it is inconsistent with our history and tradition under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), and United States Case: 25-30324 Document: 70-1 Page: 2 Date Filed: 06/02/2026 No. 25-30324 v. Rahimi, 602 U.S. 680 (2024), which he says supports, rather than proscribes, his right to possess a firearm inside his home. The district court denied his motion, and Squire pleaded guilty and was sentenced. Because our historical tradition supports disarming drug traffickers based on their dangerousness, we AFFIRM the judgment of conviction and sentence. I On February 15, 2024, a shooting occurred in New Orleans. Ten days later, officers with the New Orleans Police Department (“NOPD”) searched Squire’s home pursuant to a search warrant alleging his involvement. In executing the warrant, NOPD officers found a handgun inside Squire’s home. Tests confirmed that the firearm kept inside the home was not linked to the shooting, so the state charges related to the shooting were dismissed. On March 8, 2024, Squire was charged in a single-count federal indictment with possessing a firearm and ammunition after being convicted of a felony offense in violation of 18 U.S.C. § 922(g)(1). The indictment alleged that Squire had prior felony convictions in two state cases. In one case, he had prior felony convictions for a conspiracy and substantive count of possession with the intent to distribute heroin, a conspiracy and substantive count of possession of a firearm with a controlled dangerous substance, a conspiracy and substantive count of obstruction of justice, and a conspiracy count to possess stolen things. In another case, he had convictions for simple burglary and unauthorized use of a motor vehicle. Squire moved to dismiss the indictment. He brought numerous constitutional challenges, including one under the Second Amendment that disarmament of a citizen in his home, regardless of his felon status, is “inconsistent” with Bruen. The district court denied his motion. 2  Case: 25-30324 Document: 70-1 P