Michael Thomas McCowan v. United States
Whether a conviction for a § 922(g)(1) offense that bars firearm possession for individuals with prior criminal records violates the Second Amendment when applied to a defendant on supervised release
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 whose predicate conviction according to the criminal complaint was for a prior § 922(g)(1) offense. The court of appeals upheld petitioner’s conviction, citing its precedent that §922(g)(1) can be constitutionally applied to defendants still on supervised release at the time of the § 922(g)(1) offense. This case presents an important issue concerning the scope of a fundamental right that has divided the courts of appeals. An extension of the deadline to file a petition for certiorari will enable petitioner to thoroughly brief the matter so that this Honorable Court has as full a picture of the current legal landscape as possible. For these reasons, petitioner respectfully requests that an order be entered extending his time to petition for certiorari in the above-captioned case to and including March 5, 2026. Respectfully submitted. SHANNON LOCKE State Bar No. 24048623 15600 San Pedro Avenue, Suite 105 San Antonio, Texas 78232 Tel: 210-229-8300 Fax: 210-229-8301 Counsel for Petitioner CERTIFICATE OF SERVICE Thereby certify that on this the December 17, 2025, have served a copy of the enclosed Application for Extension of Time to File a Petition for Writ of Certiorari on all parties required to be served by enclosing a copy of each in an envelope and delivering it to United States Postal Service 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 /s/ SHANNON LOCKE Shannon Locke