After Rahimi remand, Eighth Circuit panel again rejects Second Amendment challenge to federal felon in possesion charge

Thanks to the tip from a helpful commentor, I just saw that an Eighth Circuit panel today issued a significant ruling rejecting, yet again, a federal criminal defendant's claim "that he had a constitutional right under the Second Amendment to possess a firearm as a convicted felon."  As detailed in this post last year, an Eighth Circuit panel in US v. Jackson, first rejected this claim in June 2023 before the Supreme Court provided more guidance on the Seocnd Amendment in the Rahimi case.  The Jackson case was remanded from SCOTUS back to the Eighth Circuit after the Rahimi ruling, and today this new ruling reaches the same result.  Here is the start and close of the opinion in US v. Jackson, No. 22-2870 (8th Cir. Aug. 8, 2024) (available here):

Edell Jackson appeals his conviction for unlawful possession of a firearm as a previously convicted felon. He argues that the district court1 erred when itinstructed the jury on the elements of the offense, and when it responded to two questions from the jury during deliberations.  He also contends that he had a constitutional right under the Second Amendment to possess a firearm as a convicted felon.  We affirmed the judgment in 2023. United States v. Jackson, 69 F.4th 495 (8th Cir. 2023).

The case is now on remand from the Supreme Court for further consideration in light of United States v. Rahimi, 144 S. Ct. 1889 (2024).  Rahimi held that 18 U.S.C. § 922(g)(8), the federal prohibition on possession of a firearm while subject to a domestic violence restraining order, is constitutional on its face.  Rahimi does not change our conclusion in this appeal, and we again affirm the judgment of the district court....

In sum, we conclude that legislatures traditionally employed status-based restrictions to disqualify categories of persons from possessing firearms.  Whether those actions are best characterized as restrictions on persons who deviated from legal norms or persons who presented an unacceptable risk of dangerousness, Congress acted within the historical tradition when it enacted § 922(g)(1) and the prohibition on possession of firearms by felons.  Consistent with the Supreme Court’s assurances that recent decisions on the Second Amendment cast no doubt on the constitutionality of laws prohibiting the possession of firearms by felons, we conclude that the statute is constitutional as applied to Jackson.  The district court properly denied the motion to dismiss the indictment.