Bruce James Abramski, Jr. v. United States
In brief
The Supreme Court left Abramski’s conviction in place because he falsely identified himself as the actual buyer on the dealer’s form.
- Where it stands
- Decided
Decided 5-4 · June 16, 2014 · Opinion by Justice Kagan
- What it’s about
- Bruce Abramski bought a handgun for his uncle but told the licensed dealer he was the actual buyer.
- Who it affects
- The ruling means licensed dealers must keep the actual buyer’s identity in Form 4473 records; Abramski’s false answer violated federal law.
Summary: written with AI from the case record.
What it's about
The Supreme Court upheld Abramski’s conviction, ruling that the actual buyer’s identity mattered to the sale and had to be recorded because dealers must keep Form 4473, which asks who the actual buyer is.
Justice Scalia, who disagreed with the Court, noted that Abramski used money his uncle provided and that both men were legally eligible to possess firearms.
The federal Form 4473 asks the person buying a gun to identify the actual buyer.
Question presented
1. Is a gun buyer's intent to sell the firearm to another buyer a "material fact" under 18 U.S.C. § 922(a)(b), a firearm disclosure statute? 2. Is a federally licensed firearms dealer required to keep information regarding a purchaser's intent to sell a firearm to another person?
What the Court decided
Holding
Abramski’s misrepresentation is material under §922(a)(6). Abramski’s misrepresentation about the identity of the actual buyer concerned “information required by [Chapter 44 of Title 18 of the United States Code] to be kept” in the dealer’s records. §924(a)(1)(A). Chapter 44 contains a provision requiring a dealer to “maintain such records... as the Attorney General may... prescribe.” §923(g)(1)(A). The Attorney General requires every licensed dealer to retain in its records a completed copy of Form 4473, see 27 CFR §478.124(b), and that form in turn includes the “actual buyer” question that Abramski answered falsely. Therefore, falsely answering a question on Form 4473 violates §924(a)(1)(A). 706 F. 3d 307, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said federal rules require licensed dealers to keep a completed Form 4473, which asks who the actual buyer is. Because the law required that answer to be kept, Abramski’s false response violated the record-keeping law.
The vote
From the opinions
“Both men were legally eligible to receive and possess firearms, and Abramski transferred the gun to his uncle at a federally licensed gun dealership in compliance with state law.”
What's next
The Supreme Court has finished the case, and Abramski’s conviction remains in place.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Abramski
More questions
- What two federal laws did the Court apply?
- It said Abramski’s false statement mattered to the sale under 18 U.S.C. §922(a)(6), and violated §924(a)(1)(A) because dealers had to keep that information.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.