Tyler v. Hillsdale Cnty. Sheriff's Dep't, No. 13-1876 (6th Cir. 2014)Annotate this Case
Tyler was involuntarily committed to a mental institution, 28 years ago, for less than one month after allegedly undergoing an emotionally devastating divorce. He sought a declaratory judgment that 18 U.S.C. 922(g)(4) is unconstitutional as applied to him. The statute provides: It shall be unlawful for any person . . . who has been adjudicated as a mental defective or who has been committed to a mental institution . . . to ship or transport in interstate or foreign commerce, or possess in or affecting commerce, any firearm or ammunition; or to receive any firearm or ammunition which has been shipped or transported in interstate or foreign commerce. The district court dismissed. The Sixth Circuit reversed and remanded, holding that Tyler’s complaint validly states a violation of the Second Amendment. The government’s interest in keeping firearms out of the hands of the mentally ill is not sufficiently related to depriving the mentally healthy, who had a distant episode of commitment, of their constitutional rights. The government acknowledged that it currently has no reason to dispute that Tyler is a non-dangerous individual.