ORDER DENYING MOTION FOR RECONSIDERATION

SUSAN P. WATTERS, District Judge.

On April 18, 2016, Defendant Sanders, acting prose, moved the Court for return of firearms confiscated from him in 2008. His motion was denied on April 20, 2016. On April 29, 2016, Sanders moved for reconsideration.

The motion for reconsideration brings nothing new to the table. Sanders misunderstands Henderson v. United States, ___ U.S. ___, 135 S.Ct. 1780 (2015). The question in Henderson was whether the defendant would "possess" firearms in violation of 18 U.S.C. § 922(g) if, after he became a felon, he directed them to be given to a third party by exercising a "naked right of alienation—the capacity to sell or transfer his guns, unaccompanied by any control over them." Henderson, 135 S. Ct. at 1785.

Unlike Henderson, Sanders was already a felon when he possessed the firearms at issue in this case. Notably, the predicate felony for his conviction in this case was a felony conviction for being a felon in possession of firearms. See Findings and Conclusions (Doc. 93) at 6 ¶ 9. "[T]itle to property used to commit a crime (or otherwise `traceable' to a crime) often passes to the Government at the instant the crime is planned or committed." Luis v. United States, ___ U.S. ___, 136 S.Ct. 1083, 1090 (2016) (emphasis added).

Under Henderson, it would not be a violation of 18 U.S.C. § 922(g) for Sanders to direct the United States to transfer firearms to his (unnamed) heirs. But that does not matter, because Sanders has nothing to transfer. Sanders violated § 922(g) on or about April 10, 2008. See Findings and Conclusions at 8 ¶ 3. Further, the Court found the firearms seized from him were "involved in or used in [a] knowing violation of subsection ... (g) ... of section 922," so the firearms were subject to forfeiture. See 18 U.S.C. § 924(d)(1); Findings and Conclusions at 7 ¶ 8, 9 ¶ 7. Other potential claimants had an opportunity to show they held a cognizable property interest in the firearms and to seek compensation. No one did so. See Preliminary Order of Forfeiture (Doc. 95) at 2-4 ¶ 1; Final Order of Forfeiture (Doc. 121) at 1-5. All of "the proverbial sticks in the bundle of property rights," Henderson, 135 S. Ct. at 1784, undoubtedly rest in the hands of the United States.

Because he is a felon who did possess firearms in violation of 18 U.S.C. § 922(g), and because the Court found the firearms were involved in or used in a knowing violation of § 922(g), Sanders has no legally cognizable property interest of any kind in the firearms seized from him—not even a single stick in the bundle of property rights. There is nothing for him to transfer to anyone else. Henderson has no bearing on his case.

If Sanders disagrees with this ruling, his recourse lies in appeal. No further motions for reconsideration will be entertained.

Accordingly, IT IS HEREBY ORDERED that Sanders' motion for reconsideration (Doc. 168) is DENIED.