Coram v. The State of Illinois
996 N.E.2d 1057
| Ill. | 2013Background
- Coram pled guilty in 1992 to domestic battery (misdemeanor); no firearm involvement reported.
- In 2009, Coram’s FOID card application was denied under FOID Act section 8(n) incorporating 18 U.S.C. § 922(g)(9).
- Coram sought relief under FOID Act §10, arguing substantial justice and safety interests warranted issuance; a psychologist recommended relief.
- Circuit court granted relief, directing issuance of a FOID card; Department moved to vacate, arguing federal law barred relief.
- Superior court remanded for Rule 18 findings; circuit court held §922(g)(9) unconstitutional as applied to Coram; administration of relief under §10 remained unsettled.
- This Illinois Supreme Court case addresses whether Illinois state procedures can remove a federal firearms disability and thus permit a FOID card.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can §10(c) relief remove the federal disability for Coram? | Coram should be relieved under §10(c) standards. | Federal §922(g)(9) disability cannot be removed via state §10 relief. | Yes; §10(c) relief removes disability as applied to Coram. |
| Is there a statutory bar preventing relief when federal law applies? | State procedures mirror federal relief; relief should be permissible. | Incorporation of §922(g)(9) creates permanent bar via §8(n). | No permanent bar; relief available under the state scheme. |
| Is §922(g)(9) unconstitutional as applied to Coram? | Becomes unconstitutional when no meaningful relief exists. | No constitutional infirmity in facial or applied application. | Constitutional question not resolved; relief under §10 suffices. |
| Does federal-state interplay permit state courts to grant relief from federal disabilities? | States may provide relief consistent with federal framework. | State relief cannot undermine federal disability. | Congress intended coordinated state relief; no preemption preventing relief. |
Key Cases Cited
- Logan v. United States, 552 U.S. 23 (2007) (restoration of civil rights and §921(a)(20) interpretations influence exemptions)
- Beecham v. United States, 511 U.S. 368 (Supreme Court 1994) (restoration of civil rights may relate to firearms rights under §921(a)(20))
- Caron v. United States, 524 U.S. 308 (1998) (state law governs restoration of civil rights for purposes of federal sentencing thresholds)
- Bean v. United States, 537 U.S. 71 (2002) (federal agency denial cannot be equated with judicial denial absent proper mechanism)
- Skoien v. United States, 614 F.3d 638 (2010) (discussion of restoration pathways for DV misdemeanants and as-applied challenges)
- Schrader v. Holder, 704 F.3d 980 (D.C. Cir. 2013) (courts express caution about applying §922(g)(1) to long-time law-abiding individuals)
- Heller v. District of Columbia, 554 U.S. 570 (2008) (recognizes individual right to keep and bear arms but permits longstanding prohibitions)
- McDonald v. City of Chicago, 130 S. Ct. 3020 (2010) (Second Amendment applies to states; reaffirmed limits on prohibitions)
- Moore v. Madigan, 702 F.3d 933 (7th Cir. 2012) (public-carry bans must be weighed against Second Amendment rights)
- Logan v. United States, 552 U.S. 23 (2007) (restoration-of-rights provisions interact with firearms disabilities)