In Adamiak v. United States, Patrick “Tate” Adamiak, a decorated Navy veteran, was sentenced to 20 years in federal prison for possessing cut-up gun parts and a fake RPG-7. The Fourth Circuit never considered his Second Amendment arguments, treating them as foreclosed by its earlier decision upholding Maryland’s assault weapons ban, a ruling Justice Kavanaugh has called “questionable.” He asked the US Supreme Court to hear his case, and the Minnesota Gun Owners Caucus joined other gun rights organizations in an amicus brief urging the Court to grant review.
His case shows the harm of the Court waiting for issues to “percolate” in the lower courts before deciding which arms the Second Amendment protects.
Our brief makes two arguments:
- If cut-up gun parts are “firearms” for purposes of a prosecution, they are also “arms” under the plain text of the Second Amendment, and the government must justify the law with history.
- In many lower courts, the Second Amendment’s “plain text” step has become a restrictive “Goldilocks” test that lets the government escape its historical burden. Bruen is a one-step test.
We are joined in this Amicus Curiae Brief by:
- The Second Amendment Foundation
- The National Rifle Association of America
- The California Rifle & Pistol Association
- The Second Amendment Law Center
- The Citizens Committee for the Right to Keep and Bear Arms
Outcome
On May 18, 2026, the Supreme Court denied certiorari. On September 4, 2026, President Trump granted Mr. Adamiak a full and unconditional pardon, ending his 20-year sentence.
Last updated: September 4, 2026
Case Details
Case Title
Patrick Tate Adamiak v. United States of America, on petition for a writ of certiorari to the United States Court of Appeals for the Fourth Circuit.
US Supreme Court Case #
25-1190
Our Brief
On our website, you can read our Amicus Brief filed in the United States Supreme Court on May 4, 2026.
Counsel of Record
In this case, we are represented by Konstadinos T. Moros of the Second Amendment Foundation, counsel of record, with C.D. Michel and Anna M. Barvir of Michel & Associates, P.C.
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