Coram v. State of Illinois
2013 IL 113867
| Ill. | 2013Background
- In 1992 Jerry Coram pled guilty to misdemeanor domestic battery (12 months conditional discharge; $100 fine). No firearms were involved.
- In 2009 Coram applied for an Illinois FOID card; the Illinois State Police denied the application based on incorporation of federal 18 U.S.C. § 922(g)(9) (misdemeanor domestic violence firearms ban) into the FOID Act.
- Coram petitioned the Adams County circuit court under 430 ILCS 65/10 for relief; a psychologist’s report supported his fitness and the State’s Attorney did not object. The trial court ordered issuance of a FOID card.
- The Illinois Department of State Police intervened and sought to vacate, arguing federal law prohibited issuance; the circuit court nonetheless held § 922(g)(9) unconstitutional as applied to Coram because no federal relief path was realistically available to him.
- On appeal to the Illinois Supreme Court, the Court declined to decide the Second Amendment question because it construed state and federal statutes to permit state-court relief: it affirmed the FOID issuance but vacated the trial court’s constitutional holding.
Issues
| Issue | Plaintiff's Argument (Coram) | Defendant's Argument (Illinois DPS) | Held |
|---|---|---|---|
| Whether § 922(g)(9) is unconstitutional as applied to Coram | § 922(g)(9) permanently forbids him despite rehabilitation and lacks meaningful relief; violates Second Amendment and due process | § 922(g)(9) is a presumptively lawful restriction on violent offenders and is constitutional | Court did not decide § 922(g)(9) constitutionality; vacated lower court’s as-applied invalidation as unnecessary because statutory relief exists |
| Whether Illinois FOID Act §10 permits state-court relief overriding a federal-based denial | §10 allows individualized judicial review and issuance of FOID when petitioner shows he is not dangerous; thus state court can order FOID issuance | Department argued federal prohibition (incorporated via §8(n) and confirmed by §13) prevents state court from making unlawful what federal law forbids | Court held FOID Act §10 relief, properly construed, can remove the federal disability for state purposes and affirmed the FOID issuance |
| Whether FOID Act §13 ("nothing in this Act shall make lawful … otherwise prohibited by law") precludes §10 relief when denial is based on federal law | Coram: §13 cannot sensibly refer to federal laws that are expressly incorporated elsewhere in the Act; §10 hearings were available when he applied | DPS: §13 means nothing in FOID Act can override federal prohibitions, so court cannot order FOID issuance | Court rejected DPS’s reading as nonsensical in context and found no statutory bar in §13 to §10 relief as of Coram’s application date |
| Whether state relief would be preempted or ineffective absent explicit federal restoration procedure | Coram argued state procedure is a proper, implied avenue to effectuate congressional intent to allow individualized relief | DPS argued federal supremacy and precedent (e.g., Bean, Logan) limit state ability to nullify federal prohibitions | Court concluded no preemption: federal scheme and congressional intent (including §925(c) and NICS reforms) support state role; state-court relief is a valid means to effectuate relief and avoid unnecessary constitutional ruling |
Key Cases Cited
- United States v. Skoien, 614 F.3d 638 (7th Cir. 2010) (upheld §922(g)(9) facially; left open as-applied challenges for long‑law‑abiding misdemeanants)
- Logan v. United States, 552 U.S. 23 (2007) (interpreted "civil rights restored" exemption; held rights never lost cannot be "restored")
- District of Columbia v. Heller, 554 U.S. 570 (2008) (recognized an individual right to possess firearms for self‑defense while noting longstanding prohibitions are presumptively lawful)
- McDonald v. City of Chicago, 561 U.S. 742 (2010) (incorporated Second Amendment protections against the states via the Fourteenth Amendment)
- United States v. Bean, 537 U.S. 71 (2002) (held absence of ATF action precluded judicial review under §925(c) as then administered)
- Beecham v. United States, 511 U.S. 368 (1994) (held that restoration-of-rights inquiry looks to the convicting jurisdiction)
- Moore v. Madigan, 702 F.3d 933 (7th Cir. 2012) (Seventh Circuit emphasized broader bear‑arms protections outside the home)
- Schrader v. Holder, 704 F.3d 980 (D.C. Cir. 2013) (declined to resolve as‑applied Second Amendment challenge; noted potential vulnerability of §922 bans without relief mechanisms)