In the Matter of McCloy

Summary

The court held that an out-of-State conviction is evaluated against Maryland law in effect when the firearm application was submitted, rather than when the applicant was convicted. It adopted an elements-based equivalency analysis, allowing consideration of conclusive conviction-specific facts only when the out-of-State offense is broader than the Maryland offense. Applying that framework, the court concluded that the applicant's federal conviction was not equivalent to the Maryland offense identified by the agency and ordered reversal of the firearm-application disapproval.