Escamilla v. U.S.

Dist. Ct. did not err in granting defendant-government’s motion for summary judgment in plaintiff’s action under 18 USC section 925 that sought order directing government to approve plaintiff’s attempted online purchase of handgun, where government’s denial was based on its finding that plaintiff was prohibited from possessing handgun pursuant to 18 USC section 922(g)(4) as either person who had been adjudicated as mental defective or person who had been committed to mental institution. Record showed that: (1) plaintiff had previously been examined by doctor and admitted to inpatient mental health unit under New York State Mental Hygiene Law; (2) doctor’s notes indicated during said stay, plaintiff was experiencing auditory hallucinations, depression and suicidal thoughts with plans to carry them out; and (3) plaintiff was discharged 11 days later with diagnoses of mild depressive disorder, social anxiety disorder, panic disorder and autism spectrum disorder. Ct. of Appeals held that because plaintiff was involuntarily “committed to mental institution” by lawful authority under New York law, section 922(g)(4) prohibited him from possessing handgun.