Whether a federal statute prohibiting firearm possession by individuals with prior felony convictions, including non-violent offenses, violates the Second Amendment's protection of individual rights

No question identified. : of “a crime punishable by imprisonment for a term exceeding one year” from possessing a firearm, violates the Second Amendment either facially or as applied to an individual with convictions for non-violent offenses. The court of appeals determined that § 922(g)(1) is constitutional both facially and as applied to Petitioner. This is an important issue concerning the scope of a fundamental right that has divided the courts of appeals. 3. Petitioner was represented in the district court and court of appeals by the Federal Public Defender for the Western District of Texas and is represented in this Court by Assistant Federal Public Defender Kristin L. Davidson, a member of the Bar of this Court. Since the Fifth Circuit handed down its decision on April 21, counsel has been engaged in many matters in this Court and the Fifth Circuit, limiting the amount of time she has been able to devote to preparing the petition in this case. Counsel has filed eight briefs in the Fifth Circuit, as well as four petitions for certiorari in this Court. Between now and the current July 21, 2025, deadline, counsel has two opening briefs and two reply briefs due in the Fifth Circuit. And between July 21 and August 20, 2025, counsel has an oral argument before the Fifth Circuit and one petition for certiorari in this Court, with more briefing notices likely to issue during that time. In addition, counsel will be out of the office for family commitments July 28 through August 1. For these reasons, Petitioner respectfully requests that an order be entered 2 extending his time to petition for certiorari in the above-captioned case to and including August 20, 2025. Respectfully submitted, MAUREEN SCOTT FRANCO Federal Public Defender KRISTIN L. DAVIDSON Assistant Federal Public Defender Counsel of Record OFFICE OF THE FEDERAL PUBLIC DEFENDER WESTERN DISTRICT OF TEXAS Counsel for Petitioner June 26, 2025 CERTIFICATE OF SERVICE I, a member of the Bar of this Court, certify that on June 26, 2025, I served a copy of this Application on Counsel for the United States on all parties required to be served by enclosing a copy of each in an envelope and delivering it to FedEx, a third party commercial carrier, for delivery within three calendar days to: Solicitor General of the United States U.S. Department of Justice 950 Pennsylvania Avenue, NW, Room 5614 Washington, D.C. 20530 (202) 514-2203 /s/ Kristin L. Davidson KRISTIN L. DAVIDSON Assistant Federal Public Defender Western District of Texas 300 Convent St., Ste. 2300 San Antonio, Texas 78205 Tel.: (210) 472-6700 Fax: (210) 472-4454