## Facts

- In the early 1980s, Clifford Charles Tyler suffered a severe depressive episode after a divorce.
- A Michigan probate court found Tyler mentally ill and dangerous and ordered him involuntarily committed to a mental institution for about 30 days.
- Federal law, 18 U.S.C. § 922(g)(4), bars firearm possession by anyone previously committed to a mental institution, triggering a lifetime disability for Tyler.
- Over the next three decades, Tyler was discharged, worked and retired, remarried, and alleged he had no further mental-health episodes and a current “clean bill of mental health.”
- Tyler sought restoration of firearm rights through the relief-from-disabilities path contemplated by federal law, but Congress had defunded the federal process and Michigan had no qualifying alternative relief program.
- Tyler alleged the lifetime ban, with no workable avenue for individualized restoration, violated the Second Amendment as applied to him.

## Issues

1. Whether a person involuntarily committed decades earlier, who alleges current mental stability, is categorically outside the Second Amendment’s protection for purposes of § 922(g)(4).
2. If the Second Amendment applies, what level of constitutional scrutiny governs an as-applied challenge to § 922(g)(4) in these circumstances.
3. Whether Tyler plausibly stated an as-applied Second Amendment claim sufficient to survive dismissal under Rule 12(b)(6).

## Decision

- The en banc Sixth Circuit reversed the district court’s Rule 12(b)(6) dismissal and remanded.
- The court held Tyler was not categorically excluded from Second Amendment protection solely due to a decades-old, brief commitment.
- The court directed that intermediate scrutiny applies to Tyler’s as-applied challenge.
- At the pleading stage, the government’s justification was insufficient to defeat Tyler’s claim without factual development; further proceedings were required.

## Legal Principles

- Courts may use a two-step Second Amendment analysis: (1) determine whether the regulated conduct falls within the Second Amendment’s scope; (2) if it does, apply an appropriate level of means-end scrutiny.
- “Presumptively lawful” firearm restrictions are not necessarily immune from as-applied Second Amendment challenges.
- Intermediate scrutiny places a demanding burden on the government to show a reasonable fit between the law and important public interests (including preventing gun violence and suicide); general assertions and unsupported assumptions are inadequate.
- A lifetime, categorical firearms ban based on a past commitment may be constitutionally suspect as applied to a person alleging long-term recovery, particularly where no functioning mechanism exists for individualized relief.

## Conclusion

The Sixth Circuit held that a decades-old involuntary commitment does not automatically remove a person from Second Amendment protection and that Tyler plausibly alleged § 922(g)(4) is unconstitutional as applied to him; the case was remanded for application of intermediate scrutiny on a developed record.


Tyler v. Hillsdale Cnty. Sheriff's Dep't, 837 F.3d 678 (6th Cir. 2016) (en banc)