United States v. Dixon
Docket: No. 01-3750
Court: Court of Appeals for the Third Circuit; April 22, 2002; Federal Appellate Court
Defendant contends that his conviction under 18 U.S.C. § 922(g) is unconstitutional, arguing that it exceeds congressional authority under the Commerce Clause. Additionally, he claims that the enhancement he received for a prior felony conviction should have been presented to a jury, following the Supreme Court's ruling in Apprendi v. New Jersey. The court finds that the defendant's argument regarding the Commerce Clause is precluded by the precedent set in United States v. Singletary. Furthermore, the Apprendi argument is also rejected as it is limited by the Apprendi ruling itself, which does not apply to enhancements based on prior convictions, and is supported by the subsequent Supreme Court decision in Almendarez-Torres v. United States. Consequently, the court affirms the judgment of conviction dated October 1, 2001.