Tyler v. Hillside County Sheriff’s Department

[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.