Angelo v. District of Columbia

Defending the District of Columbia’s prohibition on carrying handguns on public transit.

Court: District of Columbia

Issue at Stake: Public transit as a sensitive place

Summary: Angelo v. District of Columbia is a challenge to the District of Columbia’s prohibition on the carrying of handguns within its public transit system. The plaintiffs argue that the prohibition violates their Second Amendment rights.

Everytown filed an amicus brief in the United States District Court for the District of Columbia in defense of D.C.’s law. The brief argues that the District’s prohibition of guns on public transit is constitutional under the approach to Second Amendment cases set out in New York State Rifle & Pistol Ass’n v. Bruen. It explains that the plaintiffs have failed to establish that their proposed conduct—carrying loaded handguns on D.C.’s crowded public transit system—falls within the Second Amendment’s plain text. The brief also argues that the proper focus for Second Amendment historical analysis, including for challenges to the District’s gun laws, is the second half of the 19th century and later periods. The historical evidence during these time periods demonstrates the long tradition of analogous sensitive-places regulations and the constitutionality of D.C.’s common-sense law.

Decision: On December 28, 2022, the court denied the plaintiffs’ motion for a preliminary injunction on standing grounds.

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