United States v. Lehman, No. 20-2009 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's conviction for making false statements to licensed firearms dealers, in violation of 18 U.S.C. 924(a)(1)(A). Prior to trial, the district court denied defendant's motion to dismiss the charges on Second Amendment grounds. Defendant argues that section 924(a)(1) is unconstitutional as applied to him because it conditioned the purchase of a firearm on a statement regarding his prior involuntary commitment to a mental institution.
The court concluded that defendant failed to raise his as-applied section 924(a)(1)(A) challenge in the district court and thus forfeited his claim. The court also concluded that there was no error in denying defendant's motion to dismiss where his as-applied challenge to the statute fails under the plain error analysis because it is far from plain or obvious that the Second Amendment protects defendant's conduct - making a false statement or disregarding ATF Form 4473 to obtain a firearm.
Court Description: [Grasz, Author, with Kelly and Kobes, Circuit Judges] Criminal case - Criminal law. Defendant did not raise his claim that 18 U.S.C. Sec. 924(a)(1)(A) is unconstitutional as applied to him before the district court, and the claim is forfeited; his as-applied challenge to the statute fails under the plain error analysis as it is far from plain or obvious that the Second Amendment protects defendant's conduct - making a false statement or disregarding ATF Form 4473 to obtain a firearm.
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