Brinson v. Garland

Background

Brad Daniel Brinson sued Merrick B. Garland and other defendants, including California Attorney General Rob Bonta, over the alleged denial of a lawful firearm purchase. Brinson brought claims under 18 U.S.C. § 925A for an erroneous firearm denial, the Second Amendment, and the Fourteenth Amendment’s equal-protection provision. He sought declaratory and injunctive relief.

Brinson sued Bonta in his official capacity. The complaint alleged that the California Department of Justice conducts firearm background checks for California firearms dealers and that Bonta had supervisory authority over state officials and agencies involved in the firearm background-check system.

Motion and analysis

Bonta moved to dismiss all claims against him under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The court explained that a complaint must allege facts making it plausible—not merely possible—that the defendant is liable for the alleged misconduct.

The court found that the complaint failed to state a claim against Bonta because it did not allege facts supporting a reasonable inference that the California Department of Justice was responsible for the decision at issue. The complaint stated that Brinson did not know whether the Federal Bureau of Investigation, the California Department of Justice, or both had denied him the purchase. It also alleged only that the California Department of Justice was designated to conduct firearm background checks for firearms dealers in California.

The court concluded that the complaint did not explain what authority the California Department of Justice had after receiving information from the federal National Instant Criminal Background Check System. In particular, it did not plausibly allege that the California Department of Justice interpreted and applied the federal definition of a misdemeanor crime of domestic violence. Because the alleged 2018 denial rested on an allegedly erroneous interpretation of 18 U.S.C. § 922(g)(9), the court identified the federal government as an alternative explanation for who made the decision.

The court also found that Brinson’s general allegations that both defendants were responsible for administering firearm laws, had erroneously denied him a sale, and continued to deny his rights did not establish Bonta’s responsibility. The allegations concerning a 2014 denial likewise did not provide enough factual detail to support the inference that the California Department of Justice was responsible for interpreting and applying the federal definition to Brinson’s purchases.

Ruling

The court granted Bonta’s motion to dismiss and dismissed Brinson’s claims against Bonta, with leave to amend. The court stated that it would discuss the deadline for amending the complaint at the case-management conference scheduled for October 26, 2023. The order disposed of Docket No. 15.