Pennsylvania State Police v. Paulshock

Justice NEWMAN,

Concurring and Dissenting.

I concur in the result reached by the Majority, but must respectfully dissent from the failure of the majority to address whether the restoration of the civil rights of Paulshock by the Court of Common Pleas satisfied the exception to the federal firearm disability statute.

Federal law prohibits firearm possession following any state or federal felony conviction, even if the sentence was suspended. 18 U.S.C. § 922(g)(1) (providing that it is unlawful for any person “who has been convicted in any court of a crime punishable by imprisonment for a term exceeding one year ... to possess ... any firearm or ammunition.”). However, the federal statutes contain an explicit statutory exception that provides that the federal criminal offense of firearms possession is inapplicable to persons who have had their civil rights restored on the predicate state felony conviction. 18 U.S.C. § 921(a)(20). That statute specifically states:

(20) The term “crime punishable by imprisonment for a term exceeding one year” does not include—
(A) any Federal or State offenses pertaining to antitrust violations, unfair trade practices, restraints of trade, or *390other similar offenses relating to the regulation of business practices, or
(B) any State offense classified by the laws of the State as a misdemeanor and punishable by a term of imprisonment of two years or less.
What constitutes a conviction of such a crime shall be determined in accordance with the law of the jurisdiction in which the proceedings were held. Any conviction which has been expunged, or set aside or for which a person has been pardoned or has had civil rights restored shall not be considered a conviction for purposes of this chapter, unless such pardon, expungement, or restoration of civil rights expressly provides that the person may not ship, transport, possess, or receive firearms.

18 U.S.C. § 921(a)(20) (emphasis added). State, not federal, law determines whether an individual has had his or her civil rights restored for a state conviction. United States v. Cassidy, 899 F.2d 543 (6th Cir.1990).

The issue to be addressed in this matter is whether the Orders filed by the appropriate Courts of Common Pleas1 are sufficient to relieve all firearms disability imposed on Rodney Reed (Reed) and John Paulshock (Paulshock). Essentially, I agree with the disposition of the matter of Reed.

Federal law requires an expungement, a pardon, or the restoration of civil rights as a prerequisite for relief from a violation of the federal statutory ban on possession of firearms by a convicted felon. As used in criminal law, “expungement” means the “eradication of a record of conviction or adjudication upon the fulfillment of prescribed conditions.... It is not simply the lifting of disabilities attendant upon conviction and *391a restoration of civil rights.... It is rather a definition of status, a process of erasing the legal event of conviction or adjudication and thereby restoring to the regenerative offender his status quo ante.” Grough, Expungement of Adjudication Records 1966 Wash. U.L.Q. 147, 149. Federal case law further supports this. See Caron v. United States, 524 U.S. 308, 118 S.Ct. 2007, 141 L.Ed.2d 303 (1998) (stating that, although Massachusetts state law allows a convicted felon to have rifles after relief from firearm disabilities, Massachusetts does not permit petitioner to have handguns and, therefore, there has been no relief from federal firearms disabilities). In the matter of Reed, there is no expungement, pardon, or restoration of civil rights, only state relief from firearms disability pursuant to 18 Pa.C.S. § 61-5(d).

To obtain expungement of one’s criminal history, an individual must seek expungement pursuant to 18 Pa.C.S. § 9122, which is available when the individual: (1) “who is the subject of the information reaches 70 years of age and has been free of arrest or prosecution for ten years following final release from confinement or supervision;” or (2) “who is the subject of the information has been dead for three years.” Reed did not attain full expungement, as indicated by the Majority and, while Reed would not violate state law if he were to secure a firearm, he would still violate federal law.2 Because the State Police has the job of administering both federal and state firearms law in this Commonwealth, I believe that the Majority is correct that the State Police properly denied Reed’s application to purchase a firearm and the Commonwealth Court erred in determining that Reed’s federal firearms disability had been relieved. See 18 Pa.C.S. § 6111.1(b)(1)® (stating that it is the duty of the State Police to review the “criminal history and fingerprint records to determine if the potential purchaser ... is prohibited from receipt or possession of a firearm under Federal or State law).

*392The issue as to whether Paulshock achieved relief from firearms disability is more complex. Paulshock, who did not challenge the accuracy of his criminal history, relied upon the Common Pleas Court Order that relieved him of the firearms disability imposed by the Uniform Firearms Act on his right to purchase a firearm in the Commonwealth. Like Reed, Paulshock was relieved of his state firearm disability pursuant to Section 6105(d), but not his federal firearm disability. Thus, I would find the Commonwealth Court erred in determining that Paulshock’s federal firearm disability had been relieved.

This does not end the matter, for Paulshock returned to the Court of Common Pleas and secured an Order that stated that his civil rights were fully restored and that all firearms disability was relieved. The State Police challenges this Order because it believes that the courts of common pleas do not have the authority to restore civil rights. It is at this point that I diverge from the Opinion of the Majority. The Majority addressed only one challenge mounted by the State Police on this matter. It believes that the courts of common pleas are without authority to remove a federal firearms disability and concludes that this ends the matter. I must respectfully disagree.

As I have previously noted, the federal statute contains an explicit statutory exception providing that the federal criminal offense of firearms possession is inapplicable to persons who have had their civil rights restored on the predicate state felony conviction. 18 U.S.C. § 921(a)(20). Thus, if Paulshock succeeded in obtaining the restoration of his civil rights via an Order of the Court of Common Pleas, Section 922(g)(1) does not apply and Paulshock would not violate federal law by owning or possessing a firearm.

Federal court decisions have concluded that, for federal law to recognize state restoration of rights, the state restoration must include: (1) the right to vote; (2) the right to seek and hold public office; and (3) the right to serve on a jury. See, e.g., Hampton v. United States, 191 F.3d 695 (6th Cir.1999). If the state restoration of rights includes the three aforemen*393tioned rights, federal law contains an additional clause that looks to state law to determine whether the state imposes any further restriction on the right of the convicted felon to possess a weapon.3 If state law provides some added restriction, this federal clause is triggered to make the possession of firearms unlawful pursuant to federal law, notwithstanding the restoration of civil rights by the state.

In the instant matter, Paulshock returned to the Court of Common Pleas and secured an Order that stated that his civil rights were fully restored and that all firearms disability was relieved. The State Police challenges this Order because it believes that the courts of common pleas do not have the authority to restore civil rights. Again, I believe that, if the courts of common pleas have the authority to restore civil rights, then there is no federal firearms disability to be relieved and Paulshock is entitled to purchase firearms. The civil rights at issue, then, are the right to vote, the right to seek and hold public office, and the right to sit on a jury.

The right to vote in Pennsylvania is automatically restored upon completion of the term of imprisonment. See Mixon v. Commonwealth, 759 A.2d 442 (Pa.Cmwlth.2000), aff'd per curiam, 566 Pa. 616, 783 A.2d 763 (2001). The disqualifying factor for elector status in Pennsylvania is, inter alia, confinement in a penal institution and that disqualifying factor is removed upon release. See 25 P.S. § 2602(w); 25 P.S. § 3146.1. Therefore, Paulshock’s right to vote was restored upon his release from confinement and no order of a court of common pleas is required to effectuate the restoration of the right to vote.

Regarding the right of Paulshock to seek and hold public office and his right to serve on a jury, those rights have not been restored. Article II, Section 7 of the Pennsylvania *394Constitution provides: “No person hereafter convicted of embezzlement of public moneys, bribery, perjury or other infamous crime, shall be eligible to the General Assembly, or capable of holding any office of trust or profit in this Commonwealth.” This Court has held that the term “infamous crimes” includes felonies, and Paulshock was convicted of one or more felonies. Commonwealth ex rel Baldwin v. Richard, 561 Pa. 489, 751 A.2d 647 (2000). In Baldwin, this Court determined that the courts of common pleas were without authority to permit a plea bargain that would subvert the Pennsylvania Constitution by permitting a convicted felon to continue in public office. Further, 42 Pa.C.S. § 4502 prohibits persons convicted of crimes punishable for more than one year from sitting on a jury. No statutory relief from this abrogation of a civil right has been provided by the General Assembly. Accordingly, I must conclude that the courts of common pleas do not have the authority to restore the civil rights of a convicted felon.4

Thus, with regard to Paulshock, his civil rights have not been restored and he is ineligible, pursuant to federal law, to purchase firearms of any type. Without a restoration of civil rights, there is no official judgment evidencing the state’s renewed trust in the individual to justify putting firearms back into the hands of those who have been convicted of a felony. Hence, while I agree that the Order of the Commonwealth Court should be reversed, I must also conclude that the civil rights of Paulshock have not been restored by Common Pleas, which is without authority to restore the right to hold public office and the right to sit on a jury.

. Section 6105 of the Uniform Firearms Act, 18 Pa.C.S. § 6105, states that "[a] person ... whose conduct meets the criteria in subsection (c)(1), (2), (56) or (7) may make application to the court of common pleas of the county where the principal residence of the applicant is situated for relief from the disability imposed by this section upon the possession, transfer or control of a firearm.” Thus, Reed was required to apply to the Dauphin County Court of Common Pleas and Paulshock had to apply to the Luzerne County Court of Common Pleas for relief from State statutory firearms disability.

. If there is no procedure for restoration of civil rights contained in state statutory law, then an individual violates federal law by possessing a firearm, even if that individual has had his or her firearm disability removed pursuant to state law. Beecham v. United States, 511 U.S. 368, 373, 114 S.Ct. 1669, 128 L.Ed.2d 383 (1994).

. Some states, such as North Carolina, prohibit the subsequent possession of a handgun upon expungement or restoration of civil rights, but would allow an individual to possess a rifle or shotgun. Thus, in North Carolina, an individual could be convicted pursuant to federal law for possession of a rifle or shotgun even though it would be lawful under North Carolina law. See, e.g., Caron v. United States, 524 U.S. 308, 118 S.Ct. 2007, 141 L.Ed.2d 303 (1998).

. I note that, in December of 2002, the General Assembly enacted a provision of the Uniform Firearms Act permitting complete restoration of civil rights. 18 Pa.C.S. § 6105.1 (effective December 9, 2002). This provision, if unassailable, was enacted too late to be addressed or applied to the present matter.