Recent Decisions

The Everytown Center for the Defense of Gun Safety tracks Second Amendment cases in courts across the country. This page provides brief summaries of recent decisions in selected cases, along with links to the decisions. Earlier decisions are available here. Please get in touch with any questions you might have about these cases, or any other issues you may confront in defending gun safety laws against Second Amendment challenges.

Updates from July 8, 2025

Age Restrictions

1. McCoy v. Bureau of Alcohol, Tobacco, Firearms & Explosives, --- F.4th ----, 2025 WL 1702193 (4th Cir. June 18, 2025): Fourth Circuit holds 18 U.S.C. § 922(b)(1) (federal prohibition on licensed dealers selling handguns to individuals under 21) constitutional at history step of Bruen–Rahimi analysis; also reverses district court’s grant of class certification as untimely
   • See also Brown v. Bureau of Alcohol, Tobacco, Firearms & Explosives, No. 23-2275, 2025 WL 1704429 (4th Cir. June 18, 2025) (per curiam) (unpublished) (applying McCoy)
2. Commonwealth v. Williams, --- A.2d ----, 2025 WL 1803272 (Pa. Super. Ct. July 1, 2025): Pennsylvania intermediate appellate court rejects as-applied Second Amendment and state constitutional challenges to Pennsylvania firearms licensing statutes (18 Pa. Cons. Stat. §§ 6106, 6109), which prohibit those under 21 from obtaining a concealed-carry license, in the case of a 19-year-old defendant convicted of carrying a firearm without a license, at history step of Bruen–Rahimi analysis 

Sensitive Places

1. United States v. Allam, 140 F.4th 289 (5th Cir. 2025): Fifth Circuit holds federal law prohibiting possession of a firearm within 1,000 feet from school grounds (18 U.S.C. § 922(q)(2)(A)) constitutional as applied to defendant who “had camped out only 40 feet from school grounds” at history step of Bruen–Rahimi analysis 

Licensing

1. Hoffman v. Bonta, No. 3:24-cv-00664, 2025 WL 1811853 (S.D. Cal. July 1, 2025): federal district court holds that California law restricting non-residents from applying for concealed-carry licenses is facially unconstitutional under the Second Amendment; declines to rule on claim that the law violates the Privileges and Immunities Clause
2. People v. Thompson, --- N.E.3d ----, 2025 WL 1759061 (Ill. June 26, 2025): Illinois Supreme Court holds that Illinois’s firearms licensing regime, which requires “both a concealed carry license (CCL) and Firearms Owner’s Identification (FOID) card” to carry a firearm in public, is facially constitutional under the Second Amendment, relying on the “express endorsement of shall-issue licensure” in footnote 9 of Bruen

Prohibited Persons

1. United States v. Kimble,  --- F.4th ----, 2025 WL 1793832 (5th Cir. June 30, 2025): Fifth Circuit rejects as-applied Second Amendment challenge to 18 U.S.C. § 922(g)(1) (federal felony prohibitor) in the case of a defendant with prior convictions for violating state and federal drug-trafficking laws  
2. United States v. Drummond, No. 24-12848, 2025 WL 1825576 (11th Cir. July 2, 2025) (per curiam) (unpublished): Eleventh Circuit rejects facial and as-applied Second Amendment challenges to 18 U.S.C. § 922(g)(5) (prohibition on firearm possession by undocumented immigrants) based on pre-Bruen circuit precedent 
3. State v. Woods, --- N.W.3d ----, 2025 WL 1774280 (Iowa June 27, 2025): Iowa Supreme Court rejects as-applied Second Amendment and state constitutional challenges to Iowa law prohibiting carrying a dangerous weapon while illegally possessing a controlled substance or while committing an indictable offense, in the case of a defendant found in possession of marijuana, a scale, a loaded semiautomatic pistol, and additional high-capacity magazines   
4. State v. Cole, --- N.W.3d ----, 2025 WL 1774150 (Iowa June 27, 2025): Iowa Supreme Court rejects as-applied Second Amendment and state constitutional challenges to Iowa law prohibiting firearm possession by an individual subject to a domestic violence protective order, on ground that defendant waived those constitutional rights by expressly agreeing to terms of protective order 

Restricted Weapons

1. United States v. Greely, Nos. 1978/2042/2050, 2025 WL 1797223 (6th Cir. June 30, 2025) (unpublished): Sixth Circuit holds that 18 U.S.C. § 922(o) (federal restriction on machinegun possession) is facially constitutional under Heller and pre-Bruen circuit precedent
2.  DeWilde v. Attorney General, No. 24-8071, 2025 WL 1637695 (10th Cir. June 10, 2025) (unpublished): Tenth Circuit rejects facial challenge to 18 U.S.C. § 922(o) under the plain text of the Second Amendment 

Other Restrictions

1. Nguyen v. Bonta, --- F.4th ----, 2025 WL 1718079 (9th Cir. June 20, 2025): Ninth Circuit holds that California law limiting the purchase of firearms from licensed dealers to one firearm every 30 days facially violates the Second Amendment “because possession of multiple firearms and the ability to acquire firearms through purchase without meaningful constraints” are protected by the Second Amendment’s text and “California’s law is not supported by our nation’s tradition of firearms regulation”
2. Commonwealth v. Sumpter, --- A.2d ----, 2025 WL 1743218 (Pa. Super. Ct. June 23, 2025): Pennsylvania intermediate appellate court holds that Pennsylvania law prohibiting the unlicensed open carry of firearms in Philadelphia, which is lawful for individuals aged 18 or older elsewhere in the state, is unconstitutional under the Equal Protection Clause of the Fourteenth Amendment