History
  • No items yet
midpage
279 F.Supp.3d 281
D.D.C.
2017
Read the full case

Background

  • Plaintiff Jorge L. Medina pled guilty in 1991 to making false statements to a federally insured bank (18 U.S.C. § 1014); he received home confinement, a fine, and probation that was later terminated.
  • Because § 1014 carries a felony classification, federal law (18 U.S.C. § 922(g)(1)) bars Medina from possessing firearms despite his post-conviction rehabilitation.
  • Medina later pled guilty to state misdemeanors in Wyoming over resident hunting licenses; he claims lawful recreational firearm use (hunting/target shooting) outside California and owns property in New Mexico.
  • He filed suit (2016) seeking a declaration that § 922(g)(1) is unconstitutional as applied to him and an injunction against its enforcement; the government moved to dismiss for lack of standing and for failure to state a claim.
  • The Court found Medina has standing because § 922(g)(1) reaches conduct outside California (and Medina declared intent to possess a firearm in New Mexico), but dismissed the as-applied Second Amendment challenge on the merits.
  • On the merits the court held that convicted felons fall outside the Second Amendment’s core protections and, even if they do not, § 922(g)(1) survives intermediate scrutiny as substantially related to the important governmental interest of public safety.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Standing — traceability/redressability Medina argues § 922(g)(1) causes injury because it prevents lawful firearm possession outside California (he owns NM property and intends to possess for hunting/target shooting). Government argues California law independently bars Medina from possessing/purchasing firearms, so federal relief would not redress his injury. Court: Medina has standing — federal ban reaches beyond California and invalidation could allow lawful possession in other states (e.g., New Mexico).
As-applied Second Amendment challenge to § 922(g)(1) Medina contends a decades-old, nonviolent felony and his demonstrated rehabilitation make application of § 922(g)(1) to him unconstitutional. Government contends felons are historically unprotected, § 922(g)(1) is a longstanding categorical prohibition, and it satisfies intermediate scrutiny; individualized exceptions would be unworkable. Court: Dismissed complaint — felons fall outside core Second Amendment protections; § 922(g)(1) survives intermediate scrutiny and is constitutional as applied to Medina.

Key Cases Cited

  • District of Columbia v. Heller, 554 U.S. 570 (recognizes individual right to bear arms but affirms longstanding prohibitions like felon disarmament)
  • McDonald v. City of Chicago, 561 U.S. 742 (incorporates Second Amendment against the states and reiterates that Heller did not cast doubt on prohibitions on felons)
  • Schrader v. Holder, 704 F.3d 980 (D.C. Cir.) (applies two-step framework and upholds felon/convicted-offender firearms prohibitions)
  • Binderup v. Attorney General, 836 F.3d 336 (3d Cir.) (discusses as-applied challenges and the high burden for felons seeking relief)
  • Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requirements and burden on plaintiff to plead and prove elements)
Read the full case

Case Details

Case Name: MEDINA v. LYNCH
Court Name: District Court, District of Columbia
Date Published: Sep 6, 2017
Citations: 279 F.Supp.3d 281; 1:16-cv-01718
Docket Number: 1:16-cv-01718
Court Abbreviation: D.D.C.
Log In
    MEDINA v. LYNCH, 279 F.Supp.3d 281