Medina v. Lynch
Civil Action No. 2016-1718
| D.D.C. | Sep 6, 2017Background
- Plaintiff Jorge L. Medina pleaded guilty in 1991 to making a false statement to a federally insured bank in violation of 18 U.S.C. § 1014; sentence included home confinement, a fine, and probation. The federal felony conviction triggers the federal felon-in-possession ban, 18 U.S.C. § 922(g)(1).
- Medina later pled guilty to three Wyoming class‑5 misdemeanors for improperly obtaining resident hunting licenses; he hunted recreationally and owns property outside California (New Mexico), where he says he would possess a firearm for hunting/target shooting.
- Medina sued in federal court (filed Aug. 2016) seeking a declaration that § 922(g)(1) is unconstitutional as applied to him and an injunction against its enforcement.
- Government moved to dismiss for lack of standing (arguing California law independently bars possession) and for failure to state a claim on the merits, defending § 922(g)(1) as facially and as‑applied constitutional.
- The court held Medina has Article III standing because § 922(g)(1) bars him from possessing firearms in some other states where California law has no extraterritorial effect and Medina declared an intention to possess firearms in New Mexico.
- On the merits the court applied the Schrader two‑step framework, concluded convicted felons fall outside the Second Amendment’s core protections, and alternatively held § 922(g)(1) survives intermediate scrutiny as applied to Medina; the complaint was dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing (traceability/redressability) | § 922(g)(1) causes injury; if invalidated Medina could lawfully possess a firearm out of California (e.g., New Mexico). | California law independently bars him from firearms, so federal ruling won’t redress his injury. | Medina has standing: § 922(g)(1) bars out‑of‑state possession; invalidation could permit lawful possession in states where California lacks jurisdiction. |
| Availability of as‑applied Second Amendment challenge | He is rehabilitated and not dangerous; § 922(g)(1) is unconstitutional as applied to him. | § 922(g)(1) is historically permissible and facially valid; many circuits reject as‑applied challenges by felons. | Court allows as‑applied challenge in principle but finds Medina fails on the merits. |
| Step One (historical scope) — whether felons fall within Amendment protection | Medina: his post‑conviction conduct shows he is a law‑abiding, responsible citizen entitled to protection. | Historical tradition disfavors firearm possession by convicted criminals; felons are not law‑abiding, responsible citizens. | Court finds historical evidence supports excluding felons from Second Amendment protection; Medina falls outside the core. |
| If protected, level of scrutiny and tailoring | Medina: if reviewed, statute must be narrowly tailored to him individually. | Intermediate scrutiny applies; Congress may lawfully apply categorical ban to felons as substantially related to public‑safety objective and individualized regime is unworkable. | Even assuming review, § 922(g)(1) satisfies intermediate scrutiny as applied to Medina; individualized assessment is unnecessary and impractical. |
Key Cases Cited
- District of Columbia v. Heller, 554 U.S. 570 (2008) (Second Amendment protects law‑abiding, responsible citizens but permits longstanding prohibitions)
- McDonald v. City of Chicago, 561 U.S. 742 (2010) (incorporation of Second Amendment and reiteration that prohibitions on felons are not cast into doubt)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements: injury‑in‑fact, causation, redressability)
- Schrader v. Holder, 704 F.3d 980 (D.C. Cir. 2013) (two‑step test for firearms regulations; upheld § 922(g)(1) and discussed possible as‑applied challenges)