## Facts

- Clifford Charles Tyler, a Michigan resident in his seventies, was involuntarily committed to a mental institution for less than one month about 28 years before suit, following an acute personal crisis.
- Because of that past commitment, federal law (18 U.S.C. § 922(g)(4)) barred him from possessing firearms or ammunition.
- Federal law contemplates an individualized restoration process (18 U.S.C. § 925(c)), but Congress had blocked funding for the federal program.
- Michigan lacked a qualifying state relief-from-disabilities program, leaving Tyler with no practical avenue for individualized relief from the federal firearms disability.
- Tyler alleged he was not presently mentally ill or dangerous and supported that claim with current mental-health evidence.
- He sought declaratory relief that § 922(g)(4), as applied to him, violated the Second Amendment and also asserted equal protection and procedural due process theories.
- The district court dismissed under Rule 12(b)(6), reasoning that the Second Amendment did not cover persons previously committed, and alternatively that § 922(g)(4) would satisfy at least intermediate scrutiny.
- Tyler appealed.

## Issues

1. Whether 18 U.S.C. § 922(g)(4)’s categorical, permanent firearm prohibition is unconstitutional under the Second Amendment as applied to a person whose involuntary commitment was brief, decades old, and allegedly resolved.
2. Whether dismissal at the pleading stage was proper where the plaintiff alleged current non-dangerousness and the absence of any realistic relief mechanism.

## Decision

- The Sixth Circuit reversed the dismissal and remanded.
- The panel held Tyler plausibly stated an as-applied Second Amendment claim challenging § 922(g)(4).
- The panel rejected the view that all persons with prior commitments are categorically outside the Second Amendment’s protection.
- At the motion-to-dismiss stage, the government had not justified applying a lifetime, unrebuttable disqualification to Tyler based solely on his remote commitment and without an available individualized relief process.

## Legal Principles

- Courts assessing Second Amendment challenges apply a two-step approach: (1) whether the regulated conduct falls within the Amendment’s historical scope, and (2) if so, whether the regulation survives the appropriate level of means–end scrutiny.
- Heller’s reference to “longstanding” restrictions on possession by “the mentally ill” being “presumptively lawful” does not categorically foreclose as-applied challenges, particularly where the individual is not currently mentally ill.
- A permanent firearm disability based only on a decades-old, brief commitment, combined with the absence of a realistic mechanism for individualized restoration, can impose a substantial burden on the right of armed self-defense.
- At the pleading stage, a plaintiff states a claim by alleging facts making it plausible that the law, as applied, lacks sufficient tailoring to the government’s interests in preventing violence and suicide.

## Conclusion

The panel concluded that Tyler’s allegations—remote and brief involuntary commitment, present non-dangerousness, and no meaningful path to regain firearms rights—were sufficient to plausibly claim that § 922(g)(4)’s lifetime ban was unconstitutional as applied, requiring further factual development on remand.


Tyler v. Hillsdale Cnty. Sheriff’s Dep’t, 775 F.3d 308 (6th Cir. 2014)