Second Amendment Update: Can You Purchase Guns for Someone Else? Can You Lie about That on Forms?

Defendant Gail Manney has a son, Razaaq, who is a convicted felon. As such, Razaaq is precluded by federal law from owning or possessing a firearm. (18 U.S.C. § 922(g)(1).) On April 21, 2021, Manney went to a gun store, a “federal firearms licensee” in Reno, Nev., and arranged to purchase seven firearms. While Manney was in the store checking out the guns, the store clerk noticed that she was continually on her cellphone, talking to someone while taking photographs of the various guns. Upon selecting the guns she wanted, Manney signed an ATF Form 4473 for each firearm, certifying that she was the actual purchaser of the firearms. It was arranged that she would pick them up at a later time in order to give the store the time needed to complete the necessary federal background check before turning the guns over to her.

In the meantime, suspecting that Manney was purchasing the firearms for someone else as a “straw purchaser,” the clerk contacted the local ATF office. An ATF special agent arranged to be present when Manney returned to pick up her guns. After Manney paid for the guns, the special agent contacted her and asked her who she purchased the guns for. Manney said she bought them for herself. Upon a consensual search of her cellphone, however, the agent found numerous incriminating WhatsApp messages between Manney and her son, discussing the firearms purchase.

Convicted in federal court of making false statements on ATF Form 4473 pursuant to 18 U.S.C. §§ 922(a)(6) and 924(a)(2), Manney appealed. On appeal, she argued that these statutes violated the Second Amendment. The issue, ....

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