U.S. v. Scheidt

Overview

(U.S. Court of Appeals for the 7th Circuit,June 7, 2024) The Seventh Circuit Court of Appeals held that the Bruen Supreme Court ruling does not compel the Court to undergo a Second Amendment review of historical gun registration requirements because requirements for transaction records are not unconstitutional. The case concerned criminal charges based on a federal criminal statute, 18 U.S.C.  § 922(a)(6), which prohibits any person from knowingly making a false oral or written statement on a fact material to a gun purchase transaction. The defendant was indicted and pled guilty to making false written statements likely to deceive a firearms dealer, and admitted to selling firearms to a man she believed was affiliated with a Mexican drug cartel. On appeal, the defendant argued that the prohibition on falsifying information on a Firearms Transaction Record was a violation of the Second Amendment. The Court affirmed the conviction without performing an historical analysis of gun registration forms because the Second Amendment does not cover Scheidt’s conduct. The Court held that the criminal statute “restricts fraudulent statements, not firearm purchases.”  Instead of performing a Second Amendment analysis, the Court concluded that “[o]rdinary information-providing requirements … do ‘not infringe’ the right to keep and bear arms,” making the Bruen historical analysis framework inapplicable. Read the full opinion here.

View all cases in the Judicial Trends in Public Health – August 15, 2024.

View all cases under “Constitutional Rights and the Public’s Health.”