Second Amendment-Full Faith and Credit Clause

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7^th Circuit Court of Appeals

Case Name: Kenneth Karwacki v. Josh Kaul

Case No.: 25-2361

Officials: Easterbrook, Scudder, and St. Eve, Circuit Judges.

Focus: Second Amendment-Full Faith and Credit Clause

The Kenneth Karwacki was convicted by a special court-martial for delivering peyote to fellow soldiers and received a bad-conduct discharge. He later applied for a permit to carry a concealed firearm in Wisconsin, but the state denied his application under Wis. Stat. § 941.29(1m)(b). That statute prohibits firearm possession by individuals convicted of offenses elsewhere that would qualify as felonies under Wisconsin law. Although Karwacki’s military conviction was classified as a misdemeanor, Wisconsin treated the underlying conduct as a felony.

Karwacki filed a federal lawsuit, arguing that this classification violated both the Full Faith and Credit Clause and the Second Amendment. The Eastern District of Wisconsin rejected his claims and entered judgment for the state.

The Seventh Circuit determined that the Full Faith and Credit Clause does not apply to court-martial convictions because they are not “judicial Proceedings of any other State,” and Congress has not prescribed their effect in state courts. The court also found that Wisconsin did not disregard the military judgment but instead imposed permissible collateral consequences under state law.

With respect to the Second Amendment, the court concluded that neither the federal nor Wisconsin statutory scheme is facially invalid. It further held that individuals convicted of distributing illegal drugs are not entitled to relief from firearm restrictions.

Decided 04/02/26

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