In a case where the defendant was convicted of felon in possession of a firearm, the court rejected his argument that the felony possession statute was unconstitutional as applied to him. The court began by rejecting the defendant’s federal constitutional claim, noting that because he is a convicted felon he cannot show that he is a law-abiding, responsible citizen under the test articulated in Hamilton v. Pallozzi, 848 F.3d 614, 623 (4^th Cir. 2017). Turning to the defendant’s state constitutional claim, the court applied the Britt analysis. It noted that the defendant’s prior felony conviction was for possessing a sawed-off shotgun in 2005, a weapon of mass destruction. It noted that although his felony conviction occurred 11 years ago, the court has held the statute is constitutional as applied to a defendant where there was a span of 18 years between the prior conviction and the possession charge. With respect to the defendant’s history of law-abiding conduct, the court noted that the defendant has been convicted of driving while impaired, simple assault, assault on a female, driving without an operator’s license, being intoxicated and disruptive, felony possession of a weapon of mass destruction, and fishing without a license. With respect to the defendant’s history of lawful possession, the record established that the defendant had been unlawfully possessing at least one firearm since 2005. He thus could not establish compliance with the statute. Considering the Britt factors, the court concluded that the statute was not unconstitutional as applied to the defendant.