Fifth Circuit Upholds Rahimi Standard for Gun Bans on Heroin Traffickers
The Fifth Circuit affirmed the Rahimi dangerousness standard for disarming heroin traffickers under federal law.
Why it matters: This ruling clarifies the legal standard for restricting firearm possession among drug traffickers, shaping Second Amendment case law and enforcement across the U.S.
- On June 2, 2026, the Fifth Circuit upheld Squire's conviction under 18 U.S.C. § 922(g)(1) applying Rahimi.
- The Supreme Court's 2024 Rahimi decision allows courts to disarm individuals deemed a credible physical threat.
- Fifth Circuit's 2025 Kimble ruling held drug traffickers categorically dangerous for firearm possession bans.
- The opinion affirmed historical tradition backing disarming drug traffickers based on dangerousness.
On June 2, 2026, the Fifth Circuit Court of Appeals affirmed the conviction of Squire, a heroin trafficker, under 18 U.S.C. § 922(g)(1), endorsing the application of the Rahimi dangerousness standard to drug traffickers.
The Rahimi standard originated from the Supreme Court’s 2024 decision in United States v. Rahimi, which permits temporary disarmament of individuals a court finds pose a credible threat to others’ safety, consistent with the Second Amendment.
Building on this, the Fifth Circuit in United States v. Kimble (2025) held that individuals convicted of drug trafficking are categorically dangerous and thus can lawfully be disarmed.
In the recent USA v. Squire decision, the court stated, “Because our historical tradition supports disarming drug traffickers based on their dangerousness, we AFFIRM the judgment of conviction and sentence,” reinforcing the scope of federal firearms prohibitions.
This ruling has significant implications for firearm possession cases involving drug offenders nationwide by setting a clear precedent that dangerousness under Rahimi extends to heroin traffickers, thereby shaping future legal arguments and enforcement strategies.
By the numbers:
- June 2, 2026 — Fifth Circuit decision date in USA v. Squire
- June 21, 2024 — Supreme Court Rahimi ruling date
- September 10, 2025 — Fifth Circuit Kimble decision date