United States v. Chamberlain – Case Brief Summary (Federal Court)

In United States v. Chamberlain, 159 F.3d 656 (1st Cir. 1998), a health clinician sought Chamberlain's involuntary admission to a mental institution on an emergency basis. Id. at 657.

In the application, the clinician indicated that "'Chamberlain has a mental illness and, due to mental illness, poses a likelihood of serious harm, on the basis that he put a loaded gun to his head and threatened his wife.'" Id.

A judge in Maine certified that the application complied with the law, and ordered the subject's admission to a mental institution for no more than five days, the maximum length of an emergency detention under Maine statutory law. Id.

After the initial five-day emergency detention, Chamberlain voluntarily admitted himself to the facility and remained there for a little over a week. Id.

Chamberlain was later arrested for possessing firearms, in violation of 18 U.S.C. § 922(g)(4). Id. He moved to dismiss the charge, arguing that he had not been "committed to a mental institution" within the meaning of the statute. Id.

Reasoning that "'commitment' occurs pursuant to procedures required by state law," id. at 658, the court said:

"We believe that the proper interpretation of the phrase, 'committed to a mental institution' should not turn primarily on the label attached by the state legislature to its procedures, but rather on the substance of those procedures." Id. at 663.

It continued:

"Thus, rather than focus on the nuances of state statutory language in interpreting 'commitment,' we look at the realities of the state procedures and construe them in light of the purposes Congress sought to accomplish by prohibiting firearm possession by someone who has been 'committed to a mental institution.'" Id.

The court focused on determining "whether identifying the state's procedures for involuntary hospitalization as a 'commitment' is reasonable and consistent with the federal policy underlying the firearms ban -- namely, to keep firearms out of the hands of those who, if permitted to possess them, would pose a risk or potential for harm." Id.

In concluding that Chamberlain was "committed" to a mental institution for the purpose of the federal statute, the court stated, id. at 664:

We reject Chamberlain's argument that a person is not "committed" for purposes of the federal firearms ban unless all of the requirements set forth in section 3864 of the Maine statute including provision of counsel, a full-blown adversary hearing, a finding by clear and convincing evidence that the person suffers from a mental illness, and a judicial order of commitment -- are satisfied. . . . To treat section 3864 detention as the only "real" commitment would come close to limiting "commitments" to cases in which a person has actually been "adjudicated a mental defective" after an adversary hearing. The statute separately bans persons who have been "adjudicated a mental defective" from owning firearms, in addition to those who have been "committed to a mental institution." . . . Requiring an adversary hearing and a judicial finding of mental illness would conflate two of the categories Congress singled out for the firearms prohibition.