Sixth Circuit Upholds Mental-Health Gun Ban

A federal appeals court says the government can still permanently disarm people adjudicated dangerously mentally ill, closing out a case that started with a Missouri hospitalization order and ended with a thwarted plot near Fort Knox.

State of play: The Sixth Circuit, which covers Kentucky, Michigan, Ohio, and Tennessee, ruled October 29th that 18 U.S.C. § 922(g)(4) — the federal ban on gun possession for anyone adjudicated "mentally defective" or involuntarily committed — doesn't violate the Second Amendment. The three-judge panel found the law lines up with historical commitment statutes that let authorities confine people deemed a danger to themselves or others.

The case: Alexander Miguel Laykovich, a Wisconsin man, was ordered into 21 days of involuntary hospitalization by a Missouri court in 2023 after being found a threat to himself and others. That triggered the federal gun ban and landed him in the NICS background check system.

A year later, a Kentucky sheriff's deputy pulled him over near Stanford for erratic driving. Laykovich was wearing body armor and a recording device, carrying knives and a gas canister, and had eight firearms in the car — six of them semi-automatic. He'd driven from Wisconsin through North Carolina with Fort Knox as his destination, according to the US Attorney's Office for the Eastern District of Kentucky. A follow-up search of his storage unit turned up 15 more guns, plus improvised explosive devices and grenades.

Prosecutors charged him under both § 922(g)(4) and § 922(g)(3), the ban on gun possession by drug users. Laykovich challenged the indictment on Second Amendment grounds. US District Judge Karen K. Caldwell rejected the challenge and sentenced him to four years in prison on the mental-health charge.

The legal question: Laykovich argued the government has too much discretion to decide who counts as "dangerous." The panel didn't buy it — at least not in his case. Judge Eric E. Murphy wrote that the court didn't need to wade into that broader debate because a narrower, well-established historical rule covered the facts directly: governments have long had authority to detain, and therefore disarm, people a court has found to be a present danger due to mental illness.

"The government may legally detain (and so effectively disarm) those who have been adjudicated a present risk to public safety due to their mental illness. And Laykovich does not dispute that he falls within this group."

What gun owners should know: This keeps § 922(g)(4) fully enforceable across four states and gives other circuits a fresh opinion to cite. It's a narrower ruling than it might look — the court leaned on the specific fact that Laykovich had been formally adjudicated dangerous by a judge, not just flagged informally. Broader challenges to how § 922(g)(4) gets applied, including cases involving old or minor commitments, remain open territory.

What to watch: Expect this ruling to show up in briefs wherever § 922(g)(4) is being challenged post-Bruen. The panel's reasoning — that narrow, historically grounded rules beat sweeping "dangerousness" arguments — is likely to become a template other circuits lean on too.