Pennsylvania State Police v. Paulshock

836 A.2d 110, 575 Pa. 378, 2003 Pa. LEXIS 2178
CourtSupreme Court of Pennsylvania
DecidedNovember 20, 2003
StatusPublished
Cited by18 cases

This text of 836 A.2d 110 (Pennsylvania State Police v. Paulshock) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pennsylvania State Police v. Paulshock, 836 A.2d 110, 575 Pa. 378, 2003 Pa. LEXIS 2178 (Pa. 2003).

Opinions

[380]*380 OPINION

Justice LAMB.

We granted discretionary review of the Commonwealth Court’s disposition of consolidated petitions for review that were filed by the Pennsylvania State Police (State Police) from decisions rendered by the Office of Attorney General (OAG), holding that orders of the respective courts of common pleas had relieved Appellees, John Paulshock (Paulshock) and Rodney Reed (Reed), of disability from purchasing, owning or using firearms. The disability arose from operation of the Uniform Firearms Act (Uniform Act), 18 Pa.C.S. § 6101 et seq., specifically 18 Pa.C.S. § 6105.1 Disability also arose pursuant to the Federal Gun Control Act of 1968 (Federal Act), 18 U.S.C. § 921 et seq., specifically 18 U.S.C. § 922. The underlying issue in this appeal is whether the order in each of the two consolidated cases was sufficient to relieve firearm disability under the Federal Act. For the reasons set forth below, we find that such orders could not relieve the federal firearms disability, and therefore, we reverse the order of the Commonwealth Court.

A person who is firearm disabled as a result of a prior conviction in accordance with 18 Pa.C.S. § 6105(a)2 was able [381]*381to seek relief from a firearm disability pursuant to Section 6105(d) by applying for such relief in the common pleas court of the county of the applicant’s principal residence. In the first of the two consolidated cases, Paulshock, in 1997, filed a petition with the Luzerne County Court of Common Pleas pursuant to 18 Pa.C.S. § 6105(a). Paulshock had a 1960 conviction for burglary, arson, larceny, and malicious mischief for which he served three years in prison. Paulshock voluntarily limited his request to long guns for sport and recreation. The District Attorney of Luzerne County did not object to Paulshock’s petition. Following a hearing, the common pleas court granted Paulshock’s petition, stating in its order:

Petitioner shall be entitled to purchase, possess, and use long guns or rifles for sporting, hunting and recreational purposes, and which were designed and manufactured for the purposes of sporting events, hunting and recreational purposes only, and when called upon to provide proof of relief of disability to possess said long gun, Petitioner may present this order as proof that disability has been waived and/or relieved.3

[382]*382Pennsylvania State Police v. Paulshock, 789 A.2d 309, 313 (Pa.Cmwlth.2001) (citing Application of Paulshock, Docket No. 2691, Trial Ct. Order August 19,1997)(footnote added).

The Commonwealth Court summarized the events that ultimately led to the Paulshock lawsuit:

On August 21,1999, Paulshock attempted to purchase a long gun for hunting but was prevented from doing so. Following a records check, the [State Police] determined that, regardless of the order relieving Pennsylvania firearms disability under the Uniform Act, Paulshock’s 1960 conviction for crimes punishable by more than two years’ imprisonment disabled him from completing the purchase under Section 922(g) of the Federal Act. Paulshock challenged the purchase denial, and, after the [State Police] confirmed its decision, Paulshock appealed to the [Office of Attorney General].4

[383]*383Pennsylvania State Police v. Paulshock, 789 A.2d at 313(foot-note added).

The setting of Reed’s case was summarized by the Commonwealth Court as follows:

Rodney Reed’s firearms disability under Section 6105 of the Uniform Act and under Section 922 of the Federal Act occurred as a result of his conviction in 1966 for malicious mischief and unlawfully carrying a firearm. He served six weeks on sentences of three to twenty-four months. In 1996, when Reed sought to acquire a handgun from a friend, the local sheriff told him that his 1966 conviction disqualified him from gun ownership. In May of 1997, Reed petitioned common pleas pursuant to Section 6105(d) of the Uniform Act for relief from firearms disability. No objection to the petition having been entered by the Dauphin County District Attorney, common pleas granted Reed’s request in an order stating, in pertinent part, as follows:
[l]t is hereby Ordered that Defendant’s Petition for Relief From Firearms Disability is GRANTED pursuant to 18 Pa.C.S. 6105(d). Petitioner RODNEY E. REED is therefore permitted to seek application for reinstatement of his firearm privileges, as his prior criminal history is hereby expunged for that purpose.
Commonwealth v. Reed, (Dauphin County Nos. 190-3S-66 and 192-3S-66, dated August 29, 1997).
After receiving common pleas’ order, Reed applied to the local sheriff for a concealed weapon permit. The weapon’s permit was initially denied but later granted after Reed supplied a copy of common pleas’ order to the sheriff. Thereafter, Reed purchased two handguns. However, in December of 1998, when Reed attempted a subsequent purchase from a friend, the local gun dealer refused to [384]*384complete the paperwork for the transfer of ownership. Based on a records check pursuant to Section 6111.1(b) of the Uniform Act, [the State Police] reported that Reed was disqualified from possessing a firearm by Section 922(g) of the Federal Act, due to his 1966 conviction for unlawfully carrying a firearm, a crime punishable by more than two years imprisonment. Reed challenged the purchase denial and [the State Police] confirmed its decision. Thereafter, Reed appealed to the Office of Attorney General (OAG), which assigned an administrative law judge (ALJ) for a hearing.

789 A.2d at 310-12 (footnotes omitted) (alteration in original).

In Paulshock’s challenge, the ALJ, who was appointed by OAG, found that the order of the Luzerne County Court of Common Pleas that exempted Paulshock from firearms disability in Pennsylvania constituted an amendment of his criminal history record that also relieved his firearm disability under the Federal Act. With respect to Reed’s challenge, the ALJ determined that the order of the Dauphin County Court of Common Pleas fully removed his firearms disability, but refused to order the State Police to enforce the complete expungement of Reed’s criminal record pursuant to Section 9122 of the Criminal History Records Information Act, 18 Pa.C.S. § 9122. The State Police appealed the ALJ orders, arguing that both of the underlying orders entered by the respective common pleas courts were insufficient to relieve Reed and Paulshock’s firearm disabilities under the Federal Act. After oral argument on the consolidated cases was presented to the Commonwealth Court en banc, the Commonwealth Court affirmed.

In its appeal of the Commonwealth Court’s holding relating to Reed, the State Police present the following issue: Did the Commonwealth Court err as a matter of law when it held that a person who was convicted of a federal firearm disabling offense and applied for relief of Pennsylvania firearms disability, pursuant to 18 Pa.C.S.

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836 A.2d 110, 575 Pa. 378, 2003 Pa. LEXIS 2178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pennsylvania-state-police-v-paulshock-pa-2003.