A federal appeals court has upheld the conviction and four-year prison sentence of Alexander Miguel Laykovich, the man deputies stopped near Fort Knox in January 2024 while he was wearing body armor and carrying eight firearms in his car. The Sixth Circuit ruled that the federal law barring certain people with mental illness from possessing guns can constitutionally apply to someone in Laykovich's circumstances, rejecting his Second Amendment challenge.
According to Law360, the court upheld the application of 18 U.S.C. § 922(g)(4) in Laykovich's case. The appeal considered whether historical laws permitting civil detention of people deemed dangerous because of mental illness could support firearm restrictions.
A Traffic Stop That Unraveled Into a Federal Case
The case traces back to a Sheriff's deputy who spotted Laykovich's vehicle repeatedly crossing traffic lines on U.S. Highway 150 west near Stanford, Kentucky, on January 25, 2024. As reported by Stars and Stripes, deputies then saw Alexander Laykovich, 26, driving erratically before pulling him over, and a search of his car turned up eight guns. He told deputies he was in the military and was going to Fort Knox but didn't have military ID on him, the outlet reported.
Police also discovered multiple knives, a loaded magazine and Percocet pills during the stop. Laykovich was also wearing body armor and a body camera at the time. He told investigators he was headed to Fort Knox to discuss a security clearance matter.
A Prior Court Order Already Barred Him From Guns
Laykovich had been prohibited from possessing firearms since January 2023, stemming from an earlier mental-health episode in St. Louis. Stars and Stripes reports that a Missouri circuit court ruled on January 27, 2023, that Laykovich had mental health issues significant enough to prohibit him from having guns. The St. Louis episode resulted in a court order barring him from possessing firearms.
His girlfriend told an officer that he had shown suicidal tendencies. The Missouri court subsequently ordered Laykovich hospitalized for 21 days and found that his mental illness created a likelihood of serious harm to himself or others, before barring him from possessing firearms. A gun dealer refused to sell him a firearm in February 2023 because of that court order, according to the same account.
Guns, a Girlfriend, and a Sentencing Fight
Despite the Missouri order, deputies searched Laykovich's car and found eight guns. A separate account from Kentucky.com says two of the guns were purchased for Laykovich by someone else in October, though it does not identify that person in the available excerpt.
Federal prosecutors charged Laykovich with unlawful firearm possession under 18 U.S.C. § 922(g)(4), the statute restricting gun ownership by people involuntarily committed to a mental institution or subject to certain mental health findings. He pleaded guilty while preserving his right to appeal. On appeal, the Sixth Circuit upheld the sentencing enhancement and affirmed a within-guidelines sentence. A district judge had considered Laykovich's military service, mental health history, childhood abuse and the danger posed by his conduct when handing down the sentence.
Unused Path to Get His Guns Back
Missouri law allowed Laykovich to petition for restoration of his firearm rights by demonstrating he no longer posed a threat, but he did not pursue that process, according to Law Commentary. Under the state's statute, such a petition must be filed in the circuit court with jurisdiction over the petitioner's residence or the court that issued the disqualifying order, and must include the circumstances of the firearm disability along with the applicant's mental-health and criminal-history records, per the Missouri Revisor of Statutes.
Part of a Broader Legal Divide
The Sixth Circuit's ruling adds to a patchwork of appellate approaches to the same federal statute. A Touro Law Review article notes that three circuits have created a split concerning the constitutionality of the law. In a similar case, the Ninth Circuit upheld the statute under intermediate scrutiny as applied to people whose involuntary commitments occurred long ago.
