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“Commitment to a Mental Institution”

7th Circuit Court of Appeals

Case Name: Stefen Escamilla v. United States of America

Case No.: 22-2208

Officials: Brennan, Scudder, and Kirsch, Circuit Judges.

Focus: “Commitment to a Mental Institution”

Escamilla attempted to purchase a handgun but was denied because he had previously been committed to a mental institution. See 18 U.S.C. § 922(g)(4). Escamilla sued the federal government, arguing that he does not satisfy either of the statute’s conditions and seeking an order directing the government to approve the firearm transfer. On cross motions for summary judgment, the district court determined that Escamilla’s prior hospitalization in a mental health unit qualified as having been committed to a mental institution, and therefore, he was prohibited from possessing firearms under § 922(g)(4). Escamilla appeals, arguing that his eleven-day hospitalization did not qualify as a commitment because he was there on a voluntary and informal basis. But the district court properly concluded that Escamilla’s hospitalization qualified as a “commit[ment] to a mental institution” under New York state law for the purposes of § 922(g)(4), warranting summary judgment for the government. Escamilla also contends that the district court abused its discretion in taxing costs against him.


Decided 03/09/23

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