United States Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms v. Galioto

477 U.S. 556
Brief Filed: 2/86
Court: Supreme Court of the United States
Year of Decision: 1986

Read the full-text amicus brief (PDF, 1.42MB)

Issue

Whether provisions of a federal crime statute which permanently prohibited any individual adjudicated as suffering from a mental defect or committed to any mental institution from receiving, transporting or shipping a firearm or ammunition in interstate commerce or being sold a firearm was unconstitutional

Index Topic

Mentally Ill and Mentally Retarded (Rights of)

Facts

Title IV of the Omnibus Crime Control and Safe Streets Act of 1968, as amended by the Gun Control Act of 1968, prohibits any individual who has been adjudicated as suffering from a mental defect or committed to any mental institution from receiving, transporting or shipping a firearm or ammunition in interstate commerce and makes it unlawful for a federal firearms licensee to knowingly sell firearms to such individuals. Galioto was committed to a mental hospital for treatment of an acute schizophrenic episode. Ten years later, a store in New Jersey refused to sell him a gun because he answered "yes" to the question of prior commitment to a mental institution. Galioto petitioned the Secretary of the Treasury for relief from the firearms disability. He included a letter from the doctor who had committed him that stated that Galioto was no longer suffering from a mental disability that would interfere with his safe handling of firearms. The Secretary refused because the release provisions of the statute were only applicable to those barred from purchasing firearms due to prior criminal behavior. Galioto filed suit claiming violation of due process and equal protections. The district court agreed with Galioto. The government appealed directly to the U.S. Supreme Court.

APA's Position

APA's amicus brief argued that: (1) because presently and formerly mentally disordered people share many characteristics with classifications considered suspect, the equal protection clause requires, at a minimum, that the classification actually further the purposes of the act; (2) the statute's sole asserted purpose was to prevent misuse of firearms by persons who were especially dangerous, but its permanent disqualification of formerly committed people was irrational because the commitment decision was at most based on unreliable predictions of short-term dangerousness; (3) no state or other federal statute imposed a permanent, non-reviewable disability solely on the basis of a history of mental disorder or commitment to a mental institution; (4) the statute did not prevent firearms abuse because individuals with no history of arrest prior to commitment are no more likely than the general population to commit violent acts; and (5) administrative convenience alone did not constitutionally justify permanent disqualification under an over-broad classification based on false, stigmatizing stereotypes.

Results

Congress amended the statute to afford administrative relief to those former mental patients who are ineligible to purchase firearms, and the U.S. Supreme Court held that the equal protection and irrebuttable presumption issues were therefore moot.