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The New Federal Firearm Rights Process, and What It Actually Does in Wisconsin

Over two days last week this office took a run of calls that all asked the same thing, which almost never happens. People wanted to know whether they could get their gun rights back.

The reason for the clustering is that on August 17, 2026 the Attorney General finalized a rule reopening a federal application process that had been dormant for more than thirty years. The coverage of it has been loose. Some of it suggests the federal government just restored rights to millions of people, and some of it suggests the change means nothing at all outside federal court. Neither is right, and the gap between them matters a great deal if you live in Wisconsin.

Here is the short version. There is now a real federal process. Wisconsin’s own statute contains an express exception that recognizes the result of that process. And no Wisconsin appellate court has ever interpreted that exception, because until last week there was no realistic way to trigger it.

What the federal government actually did

The relevant statute, 18 U.S.C. § 925(c), is old. It lets a person who is prohibited from possessing firearms apply to the Attorney General for relief, and it authorizes relief where the applicant establishes that

the circumstances regarding the disability, and the applicant’s record and reputation, are such that the applicant will not be likely to act in a manner dangerous to public safety and that the granting of the relief would not be contrary to the public interest.

The statute never went away. The ability to use it did. As the Justice Department put it in announcing the change, “For more than three decades, the statutory process Congress created under 18 U.S.C. § 925(c) was effectively unavailable to most individuals seeking relief from federal firearms disabilities.”

The final rule was published in the Federal Register on August 20, 2026 and takes effect September 21, 2026. Applications run through the Justice Department’s Federal Firearm Rights Restoration Program at justice.gov/ffrr.

Two things about it deserve emphasis, because the enthusiastic coverage has tended to skip both.

Relief is discretionary and individualized. The Department was explicit that restoration “is neither automatic nor guaranteed,” and that it maintains “strong presumptions against relief for individuals whose crimes, conduct, or status demonstrate heightened risks to public safety.” Absent extraordinary circumstances, violent felons, registered sex offenders, illegal aliens and others presenting an ongoing danger remain presumptively ineligible.

It is federal relief only. In the Department’s own words, relief granted under the rule “removes only applicable federal firearms disabilities and does not override independent restrictions imposed by state law.”

That last sentence is where most people stop reading, and where most of the confusion starts.

The Wisconsin question, which is the one that matters here

If federal relief does not override state law, the natural conclusion is that a Wisconsin resident gains nothing usable. In most states that conclusion would be roughly right. In Wisconsin it is wrong, and the reason is that Wisconsin answered the question itself.

Possession of a firearm by a person with a felony conviction is a Class G felony under Wis. Stat. § 941.29(1m). The prohibition is broad. It reaches felony convictions in Wisconsin, convictions elsewhere that would be felonies here, delinquency adjudications for conduct that would be a felony, findings of not guilty by reason of mental disease or defect, certain commitment orders, and people subject to domestic abuse, child abuse and harassment injunctions.

Then subsection (5) carves out two exceptions. This section, it says, does not apply to any person specified in sub. (1m) who:

(a) Has received a pardon with respect to the crime or felony specified in sub. (1m) or (4m) and has been expressly authorized to possess a firearm under 18 USC app. 1203; or

(b) Has obtained relief from disabilities under 18 USC 925 (c).

That is the same § 925(c) the Justice Department just reopened. Wisconsin did not have to recognize federal relief, and many states do not. Wisconsin wrote it into the statute.

So the federal rule and the Wisconsin statute are not in conflict, and the apparent contradiction dissolves once both are read together. Federal relief does not automatically override state law. It does not have to. Wisconsin law independently provides that its own prohibition does not apply to a person who has obtained that relief.

Why we are not telling anyone this is a sure thing

Everything above is what the text says. Here is what the text does not tell you, and it is the part that should govern anyone’s decision.

No Wisconsin appellate court has ever construed § 941.29(5)(b). Not once. The reason is mechanical rather than mysterious: § 925(c) relief was effectively unobtainable for more than thirty years, so no defendant ever walked into a Wisconsin courtroom holding a federal grant and asking a judge what it meant here. The subsection has sat in the statute books as a provision with nothing to attach to.

The neighboring exception has been read narrowly. In Moran v. Department of Justice, 2019 WI App 38, 388 Wis. 2d 193, 932 N.W.2d 430, the court of appeals held that Virginia’s restoration of a felon’s rights was not a “pardon” for purposes of § 941.29(5)(a). That decision does not control paragraph (b), and there is a meaningful difference between the two: a Virginia restoration had to be argued into the word “pardon,” whereas § 925(c) is named in the statute in so many words. But Moran is a fair signal about how strictly this subsection gets read, and pretending otherwise would not serve anyone.

Relief does not reach every prohibition you might have. Section 941.29(1m) sweeps in more than felony convictions. If an active injunction is what bars you, that order has its own terms and its own expiration, and federal relief aimed at a felony disability does not dissolve it. Concealed carry licensing is governed by a different statute, Wis. Stat. § 175.60, with its own eligibility criteria. Relief from one prohibition is not relief from all of them.

Put those together and you get an honest assessment rather than a pitch. There is a genuine, statutorily grounded path here. It is better grounded in Wisconsin than in most states. It has never been tested in a Wisconsin appellate court, and the penalty for getting it wrong is a new Class G felony.

The pardon route, which has not gone anywhere

Section 941.29(5)(a) still exists, and for state purposes it remains the more established path. A Wisconsin pardon is granted by the Governor, it is entirely discretionary, and it is a separate application from anything filed with the Justice Department.

The two routes are independent. Some people will want to pursue both, and depending on the record, that is sometimes the more conservative approach rather than the more expensive one.

How we are handling these cases

We are taking this work, and we are billing it hourly. We would rather explain that plainly than bury it.

The reason is that nobody can responsibly quote a flat fee for this yet. The applications are document-intensive, often requiring records from courts and agencies that have had decades to lose them. The office administering the process opened this month and has no track record to estimate against. And the Wisconsin question sitting underneath it all is unlitigated, which means the analysis in any given file may be short or may be substantial depending on what the record looks like.

A flat fee under those conditions would either overcharge the people whose files come together quickly, or leave us unable to do right by the ones that do not. When the process matures and the timelines become predictable, that calculation may change.

What we will tell you at the outset, before you spend anything, is whether your record looks like one where this is realistic. For some people it plainly is not, and that is a five-minute conversation rather than an engagement.

If you are thinking about this

A few things worth doing before you call anyone, including us.

Find out precisely what your prohibition is. A felony conviction, a delinquency adjudication, an NGI finding and an active injunction are four different legal situations under § 941.29(1m), and they do not all respond to the same remedy.

Start gathering your records now. Judgments of conviction, discharge certificates, and proof of what happened after are the raw material of any application, and they take longer to collect than people expect.

And do not acquire a firearm on the strength of a federal grant without talking to a lawyer about your specific record first. The exception you would be relying on is real, it is written in the statute, and it has never been tested in a Wisconsin appellate court. That combination calls for advice before action, not after.

If you want to know whether your situation is one where this is worth pursuing, call us. We will tell you straight, including when the answer is no.

What did the Justice Department actually change?
On August 17, 2026 the Attorney General finalized a rule reopening the application process under 18 U.S.C. § 925(c), which lets a person prohibited from possessing firearms apply for relief from the federal disability. The statute has been on the books for decades. What changed is that there is now a functioning process and an office administering it. The rule was published in the Federal Register on August 20, 2026 and takes effect September 21, 2026.
Does federal relief lift the Wisconsin prohibition?
Not by its own force. The federal rule says relief "removes only applicable federal firearms disabilities and does not override independent restrictions imposed by state law." But Wisconsin has separately written an exception into its own statute. Wis. Stat. § 941.29(5)(b) says the felon-in-possession section "does not apply to any person specified in sub. (1m) who ... has obtained relief from disabilities under 18 USC 925 (c)." So the answer turns on Wisconsin's own words, not on the federal rule.
Then a person with 925(c) relief can lawfully possess a firearm in Wisconsin?
That is what the statutory text says, and it is why this is worth pursuing. It is not the same as a guarantee. No Wisconsin appellate court has ever construed § 941.29(5)(b), because § 925(c) relief was effectively unavailable for more than three decades and so no case presented the question. Anyone relying on the exception is relying on unlitigated text.
Why does it matter that no court has ruled on it?
Because Wisconsin courts have read the neighboring exception narrowly. In Moran v. Department of Justice, 2019 WI App 38, the court held that Virginia's restoration of a felon's rights was not a "pardon" for purposes of § 941.29(5)(a). That case does not control § 925(c) relief, which is named expressly in (5)(b) rather than inferred. It does show that this subsection gets construed strictly, which is the honest reason for caution.
Is a Wisconsin governor's pardon still relevant?
Yes, and it remains the more established route for state purposes. Section 941.29(5)(a) covers a person who has received a pardon and has been expressly authorized to possess a firearm. A pardon is discretionary, it is granted by the Governor, and it is a separate application from anything federal. The two paths are independent, and some people will want both.
Who is unlikely to qualify federally?
The Justice Department stated that, absent extraordinary circumstances, violent felons, registered sex offenders, illegal aliens, and other individuals presenting an ongoing danger remain presumptively ineligible. Relief is neither automatic nor guaranteed. Each applicant has to establish that the circumstances of the prohibition, together with their record, reputation and subsequent conduct, show they are not likely to act in a manner dangerous to public safety.
Does this restore my right to carry concealed?
That is a separate question governed by a separate statute, and it should not be assumed. Concealed carry licensing in Wisconsin runs through Wis. Stat. § 175.60 and has its own eligibility criteria. Ask about it specifically rather than assuming that relief from one prohibition resolves every other one.
What if my prohibition comes from an injunction rather than a felony?
Section 941.29(1m) reaches more than felony convictions. It also covers delinquency adjudications, findings of not guilty by reason of mental disease or defect, certain commitment orders, and people subject to domestic abuse, child abuse or harassment injunctions. Relief aimed at a felony disability does not make an active injunction disappear. The order has its own terms and its own expiration.
What will this cost, and how long does it take?
We bill this work hourly, and we say so up front. The process is document-intensive, the office administering it is brand new, and nobody has a track record to price against yet. A flat fee here would either overcharge people whose files come together quickly or leave us unable to finish the ones that do not. As the process matures and timelines become predictable, that may change.
Should I just buy a gun once my federal application is granted?
No. Talk to a lawyer about your specific record first. Section 941.29 is a Class G felony, the exception you would be relying on has never been tested in a Wisconsin appellate court, and the consequence of being wrong is a new felony prosecution. Getting the paperwork right beforehand is considerably cheaper than a defense afterward.