Tyler v. Hillsdale County Sheriff’s Department

Clifford Tyler (plaintiff) was committed to a mental institution for one month after an emotionally traumatic divorce. Approximately 30 years later, Tyler attempted to purchase a firearm. Tyler’s purchase was denied because a federal law prohibited a person from possessing a firearm if the person had ever been (1) adjudicated as a mental defective or (2) committed to a mental institution. The law’s purpose was to prevent mentally ill people from committing suicide or acts of violence toward others. The law specifically allowed a person to regain the right to possess a firearm by obtaining an official ruling that the person was not dangerous. However, the federal program for restoring firearm-possession rights was not operative because it was not funded. Although Congress had provided incentives for states to implement rights-restoration programs, only some states had created these programs. Tyler lived in Michigan, which did not have a program for restoring firearm-possession rights. Therefore, although Tyler had evidence indicating that he was not dangerous and had not been mentally ill for decades, he had no access to either a federal or a state program that could restore his firearm-possession rights. Tyler sued, alleging that the federal law violated his Second Amendment rights. The district court dismissed Tyler’s suit for failure to state a claim, and Tyler appealed.