Department of Treasury, Bureau of Alcohol, Tobacco and Firearms v. Galioto
Headline: Ruling on gun purchases by former involuntarily committed mental patients vacated after Congress permits them to seek administrative relief, and the case is sent back to the lower court for more proceedings.
Holding: Because Congress amended the firearms law to allow anyone barred from guns, including some former involuntarily committed patients, to apply for administrative relief, the Court vacated the lower court’s ruling and remanded the case.
- Former involuntarily committed mental patients can apply for administrative relief to possess firearms.
- District Court’s prior ruling is vacated and is no longer in effect.
- Case returns to the District Court for further proceedings under the new law.
Summary
Background
In 1982 a man tried to buy a gun at a New Jersey store and, on a form, admitted he had been involuntarily committed to a mental hospital in 1971. The dealer refused the sale under federal firearms laws that bar people who have been committed to mental institutions from receiving firearms. The buyer sought an exemption from the Bureau of Alcohol, Tobacco and Firearms and then sued when he was denied. The District Court found parts of the federal scheme unconstitutional because felons could seek relief but former mental patients could not, and because the law created an unrebuttable presumption of dangerousness.
Reasoning
While this case was pending, Congress changed the law (Pub. L. 99-308) so that anyone barred from possessing firearms could apply to the Secretary for administrative relief, and Congress made that change apply to pending cases. Because the statute now provides a hearing and possible relief to former involuntarily committed patients, the Court concluded the earlier equal protection and irrebuttable-presumption questions were moot. The Supreme Court vacated the District Court’s judgment and remanded the case for further proceedings consistent with the new law.
Real world impact
Under the changed law, people who were involuntarily committed can seek an administrative review that may restore their ability to acquire firearms. The District Court’s decision striking parts of the statutes is no longer in force, and the lower court must consider any remaining claims in light of the new statutory procedure.
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