Wilson v. Lynch
United States Court of Appeals for the Ninth Circuit
835 F.3d 1083 (2016)
- Written by Salina Kennedy, JD
Facts
The federal Controlled Substances Act (CSA) criminalized marijuana possession. After determining that drug use increased the risk of irrational or unpredictable behavior, Congress enacted a statute prohibiting unlawful-drug users from possessing or receiving firearms and criminalizing the sale of firearms to any person the seller knew or had reasonable cause to believe was an unlawful-drug user. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) (defendant) promulgated regulations defining marijuana users as unlawful-drug users and issued a letter (the letter) stating that an individual’s possession of a state marijuana-registry card provided a firearms seller with reasonable cause to believe that the individual was an unlawful-drug user. S. Rowan Wilson (plaintiff) acquired a Nevada marijuana-registry card and subsequently attempted to purchase a gun. The seller knew about Wilson’s medical-marijuana card and, citing ATF guidance, refused to sell Wilson the gun. Wilson filed a lawsuit in federal district court challenging the letter’s constitutionality. Rowan argued that the letter violated her Second Amendment rights, asserting that although she possessed a registry card, she chose not to use medical marijuana and was therefore not an unlawful-drug user. The district court granted the ATF’s motion to dismiss, and Wilson appealed.
Rule of Law
Issue
Holding and Reasoning (Rakoff, J.)
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