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. New decisions are added approximately every two weeks. 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 August 12, 2025

Prohibited Persons

1. United States v. Simmons, --- F.4th ----, 2025 WL 2301317 (2d Cir. Aug. 11, 2025): Second Circuit upholds 18 U.S.C. § 922(g)(9) (misdemeanor crime of domestic violence prohibitor), both facially and as applied to defendant, at history step of Bruen-Rahimi framework
2. United States v. VanOchten, --- F.4th ----, 2025 WL 2268042 (6th Cir. Aug. 8, 2025): Sixth Circuit rejects as-applied challenge to 18 U.S.C. § 922(g)(3) (prohibition on firearm possession by unlawful drug users) at history step of Bruen–Rahimi framework, in the case of a defendant who “demonstrated that he poses a clear risk of future harm to others if armed” by, on the day of his arrest, “fir[ing] a rifle in a residential neighborhood in the direction of a propane tank while drunk and high”
3. United States v. Morgan, --- F.4th ----, 2025 WL 2233205 (5th Cir. Aug. 6, 2025): Fifth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(g)(1) (federal felony prohibitor) at history step of Bruen-Rahimi framework, in the case of a defendant with a prior conviction for “illegal use of a weapon—specifically, a drive-by shooting that struck a victim’s home and car”
4. United States v. Gould, --- F.4th ----, 2025 WL 2110902 (4th Cir. July 29, 2025): Fourth Circuit holds that 18 U.S.C. § 922(g)(4) (federal mental-health prohibitor) is facially constitutional at history step of Bruen-Rahimi analysis

Licensing and Public Carry

1. Yukutake v. Lopez, --- F.4th ----, 2025 WL 2102541 (9th Cir. July 28, 2025): Ninth Circuit vacates panel opinion that had held two provisions of Hawai‘i’s firearms licensing regime facially unconstitutional and orders rehearing en banc
2. O’Neil v. Neronha, No. 1:23-cv-00070, 2025 WL 2197313 (D.R.I. Aug. 1, 2025): rejects as-applied challenges to Rhode Island’s licensing requirements for open carry at history step of Bruen-Rahimi framework, in case of plaintiffs denied open-carry licenses who already held concealed-carry licenses

Sensitive Places

1. People v. Temple, --- N.E.3d ----, 2025 WL 2271840  (Ill. App. Ct. Aug. 8, 2025): Illinois intermediate appellate court rejects facial Second Amendment challenge to state law prohibiting the possession of firearms in public parks at history step of Bruen-Rahmi framework

Assault Weapons and Large-Capacity Magazines

1. Recchia v. Campbell, No. 1:24-cv-12560, 2025 WL 2229393 (D. Mass. Aug. 5, 2025): dismisses challenge to Massachusetts law prohibiting the importation and sale of assault weapons and large-capacity magazines under post-Bruen First Circuit precedent; also rejects dormant Commerce Clause and equal protection claims

Other Restricted Weapons

1. United States v. Bridges, --- F.4th ----, 2025 WL 2250109 (6th Cir. Aug. 7, 2025): Sixth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(o) (federal restriction on machine gun possession) under controlling Supreme Court and Sixth Circuit precedent that “predates Bruen but remains good law” and, independently, at history step of Bruen–Rahimi framework
2. State v. Jones, --- N.W.3d ----, 2025 WL 2202241 (Minn. Ct. App. Aug. 4, 2025): Minnesota intermediate appellate court holds that state law prohibiting defendant’s possession of a “ghost gun”—i.e., “a privately made firearm without a serial number”— does not violate the Second Amendment, at history step of Bruen-Rahimi analysis

Other Restrictions

1. Urbana v. Rangel, No. 03-23-00449-CV, 2025 WL 2087207 (Tex. App. July 25, 2025): Texas intermediate appellate court rejects Second Amendment challenge to custody order requiring secure storage of firearms and prohibiting firearm carry during child exchanges at history step of Bruen-Rahimi analysis