United States v. Michael Adams, 698 F.3d 965

Adams convicted of unlawful firearm possession under 18 U.S.C. §922(g) and sentenced as an armed career criminal under §924(e) based on four prior felonies.
Two of Adams’s four qualifying felonies (1981–1982 robberies) occurred under Illinois law before a 1984 state-law change that restricted felons’ firearms rights.
Illinois repealed its prior firearms-ownership provisions in 1984; post-1984, felons may possess firearms only with express state permission.
Illinois courts held the 1984 law applies to pre-1984 convictions for purposes of civil-rights restoration, meaning Adams’s firearms-rights were not restored.
§921(a)(20) excludes certain state offenses from “crime punishable by imprisonment for a term exceeding one year” when civil rights have been restored or expunged, and post-conviction events matter for restoration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post-conviction Illinois law changes affect §921(a)(20) restoration	Melvin/Walden should be overruled due to confusion from state-law changes.	Restoration depends on state law as it stood at the time of potential restoration; changes post-conviction are relevant.	No; post-conviction state-law changes can affect restoration and count toward §921(a)(20).
Whether Caron equates restoration by document with restoration by law	Caron says restoration by document can remove a conviction from federal consideration.	Caron distinguishes restoration by operation of law from express documents; not dispositive here.	Caron does not require ignoring state-law status on date of restoration; post-conviction events matter.
Whether McNeill dictates ignoring post-conviction developments for §921(a)(20)	McNeill supports ignoring post-conviction developments in applying §924(e).	McNeill concerns §924(e)(2)(A)(ii), not §921(a)(20); post-conviction restorations are relevant under §921(a)(20).	McNeill does not preclude §921(a)(20) consideration of restoration status.
Whether Adams’s 1981–1982 convictions count under §921(a)(20)	Because civil rights were restored under state law at some point in Illinois, these convictions should be disregarded.	Illinois law never restored Adams’s firearms rights; thus the convictions count.	Adams’s firearms-rights were not restored under Illinois law; §921(a)(20) counts these convictions.

Melvin v. United States, 78 F.3d 327 (7th Cir. 1996) (rejection of restoring rights argument under §921(a)(20))
United States v. Walden, 146 F.3d 487 (7th Cir. 1998) (reaffirming Melvin approach to restoration of civil rights)
Caron v. United States, 524 U.S. 308 (1998) (restoration by operation of law treated for §921(a)(20))
McNeill v. United States, 131 S. Ct. 2218 (2011) (state law at time of crime determines ‘serious drug offense’; post-conviction developments not ignored for §924(e)(2)(A)(ii))
Buchmeier v. United States, 581 F.3d 561 (7th Cir. 2009 (en banc)) (post-conviction documents and restoration language discussed in §921(a)(20) context)
United States v. Burnett, 641 F.3d 894 (7th Cir. 2011) (restoration of civil rights and firearms proviso discussed under §921(a)(20))