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Tyler v. Hillside County Sheriff’s Department
United States Court of Appeals for the Sixth Circuit
837 F.3d 678 (2016)
[Editor’s Note: Firearms Law and the Second Amendment (Nicholas J. Johnson et al. eds., 3d ed. 2021) incorrectly uses “Hillside” instead of “Hillsdale” in the name of the case.] After an emotional divorce, Clifford Tyler (plaintiff) experienced a serious depressive episode. A probate court determined that Tyler was mentally ill and potentially a danger to himself and others. Tyler was involuntarily committed to a mental institution. This triggered a federal statute, 18 U.S.C. § 922(g), which made it unlawful for anyone who had been committed to a mental institution to possess a firearm. Tyler spent 30 days in the institution, after which he held a job for several years, remarried, and experienced no further mental issues. Tyler petitioned the federal government to restore his firearm rights but had no success, even though the gun-control statute provided for a program for having the disqualification lifted. Tyler brought an action against the Hillsdale County Sheriff’s Department (defendant) in federal district court. The court dismissed the action for failure to state a claim. Tyler appealed to the United States Court of Appeals for the Sixth Circuit. A panel of that court applied strict scrutiny and held that the mental-illness disqualification violated the Second Amendment of the United States Constitution. The same court then heard the case en banc.
Rule of Law
Holding and Reasoning (Gibbons, J.)
Concurrence (Batchelder, J.)
Concurrence (White, J.)
Concurrence (McKeague, J.)
Concurrence (Sutton, J.)
Concurrence (Boggs, J.)
Dissent (Rogers, J.)
Dissent (Moore, J.)
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