In US v. Miller, the court found that the National Firearms Act of 1934 was Constitutional. The question I have is, why wasn't it dismissed considering that Miller died before the case was heard?

Wouldn't that make the case moot?

1 Answer 1


Miller was only one of the defendants

Two people were charged with the crime, Miller and Laycock. Miller was dead, Laycock was still alive. Following the Supreme Court decision:

On January 8, 1940, Layton pleaded guilty to the reinstated NFA charge and Ragon sentenced him to five years probation.

So the case was not at all moot.

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