United States v. Ronnie Dean Purdy

Ronnie Dean Purdy (“Purdy”) challenges the constitutionality of his federal court conviction as “an unlawful user of ... a[ ] controlled substance” in possession of a firearm, in violation of 18 U.S.C. § 922 (g)(3). Specifically, Purdy claims that he was convicted in violation of due process because the definition of “unlawful user” contained in § 922(g)(3) is too vague to supply him with adequate notice that his conduct was prohibited. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

I.

FACTS and PROCEDURAL HISTORY

On July 8, 1999, Drug Enforcement Administration (“DEA”) agents responded to a report that a methamphetamine laboratory was operating out of a house located at 442 Plank Road in Toppenish, Washington. The agents went to the house and interviewed Purdy, who stated that he lived there alone. The agents searched the house and found a .22 caliber rifle on the table in the living room and a glass pipe containing methamphetamine residue. In later interviews, Purdy told the agents that he was the owner of the .22 caliber rifle, that he used marijuana, and that he used methamphetamine and “everybody knew it.”

On September 14, 1999, Purdy was indicted by a…