State v. Burris

Summary

The court held that the 15-year exception for certain former felons in the felony firearm-possession statute does not apply to the separate misdemeanor offense of unlawful possession of a firearm. Although the misdemeanor statute cross-references the felony statute, legislative history showed that the cross-reference originated as a non-substantive codification artifact and was not intended to incorporate the felony statute's exceptions. The court therefore upheld the exclusion of evidence supporting defendant's claimed exception and affirmed.