United States v. Patrick Bridges, 696 F.3d 474

Bridges, convicted of misdemeanor domestic violence in Michigan in 2001, received probation but no incarceration.
In 2010 Bridges was indicted under 18 U.S.C. § 922(g)(9) for possessing a firearm after his domestic violence misdemeanor conviction.
Bridges moved to dismiss the indictment, arguing he falls within an exception in § 921(a)(33)(B)(ii) because civil rights were not lost or restored.
Michigan law provided civil rights are lost only while confined; Bridges’ civil rights were not taken away due to confinement.
The district court denied the motion; Bridges pleaded guilty with a reservation to appeal the denial and was sentenced to 21 months.
The appellate court applied de novo review to statutory interpretation and affirmed, following Logan v. United States and related precedents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bridges qualifies for the civil-rights restoration exception.	Bridges contends the exception applies to those who never lost civil rights.	Bridges’ rights were not restored because they were never removed, and Logan controls.	No; Bridges does not qualify.

United States v. Wegrzyn, 305 F.3d 593 (6th Cir. 2002) (addressed civil-rights restoration in similar context)
Logan v. United States, 552 U.S. 23 (Supreme Court 2007) (civil-rights restored clause does not apply to those who never lost civil rights)
Smith v. Cupp, 430 F.3d 766 (6th Cir. 2005) (binding reasoning following Logan)
Roberts v. Hamer, 655 F.3d 578 (6th Cir. 2011) (statutory-interpretation review standard)