Shawano Gun & Loan LLC v. Hughes

Dist. Ct. properly granted defendant's motion for summary judgment in administrative appeal by plaintiff-firearm shop owner of defendant's revocation of plaintiff's license to sell firearms based on plaintiff's willful failure to keep accurate records of firearm sales as required by Gun Control Act. Record showed that: (1) plaintiff on at least two separate audits by defendant failed to keep accurate records of firearms sales and had failed to recognize straw purchases of guns by customers who were not intended purchasers of said guns; and (2) said multiple failures were sufficient to establish willful violation under 18 USC section 923(e). Ct. rejected defendant's argument that willful element in statute required showing that defendant's acts were more than inadvertent errors or technical mistakes.