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. Sign up here to receive these updates by email. 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 February 6, 2026

Sensitive Places

1. Kipke v. Moore, --- F.4th ----, 2026 WL 143528 (4th Cir. Jan. 20, 2026): Fourth Circuit upholds constitutionality of Maryland laws prohibiting guns in numerous sensitive places, including in state parks and forests, at or within 1,000 feet of a public demonstration, on public transit, at healthcare facilities, and at locations that sell alcohol for on-site consumption, at history step of Bruen–Rahimi framework; holds unconstitutional Maryland’s prohibition on carrying firearms on private property open to the public absent the owner’s express consent; Judge Agee concurs in part and dissents in part

Restricted Weapons

1. Knife Rights v. Bonta, --- F.4th ----, 2026 WL 250188 (9th Cir. Jan. 30, 2026): Ninth Circuit rejects facial challenge to California law restricting the possession, sale, transfer, and carry of switchblade knives at history step of Bruen-Rahimi framework, holding that the law’s “prohibition on the concealed carry of switchblades is relevantly similar to historical concealed carry regulations of Bowie knives, dirks, daggers, slungshots, and other weapons”
2. United States v. Reyna, --- F.4th ----, 2026 WL 221850 (7th Cir. Jan. 28, 2026): Seventh Circuit rejects facial challenge to 18 U.S.C. § 922(k) (prohibition on possessing a firearm with an obliterated serial number) at history step of Bruen-Rahimi framework, finding the regulation “loosely but relevantly similar to founding-era laws and practices requiring firearms to be marked or stamped, inventoried, and inspected”
3. United States v. Wilson, 164 F.4th 380 (5th Cir. 2026): Fifth Circuit rejects facial challenge to 18 U.S.C. § 922(o) (federal restriction on machinegun possession) under pre-Bruen circuit precedent; Judge Willett, author of the majority opinion, also separately concurs to “note [his] doubts” about prior circuit precedent upholding § 922(o) as a valid exercise of Commerce Clause power, and to call for its reconsideration in a future case; Judge Ho files separate opinion expressing similar “concerns” under both the Commerce Clause and the Second Amendment
4. United States v. Fisher, No. 24-4527, 2026 WL 74584 (4th Cir. Jan. 9, 2026) (per curiam) (unpublished): Fourth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(o) (federal restriction on machinegun possession) at text step of Bruen-Rahimi framework
5. People v. McCowan, --- Cal. Rptr. 3d ----, 2026 WL 92012 (Cal. Ct. App. Jan. 13, 2026): California intermediate appellate court rejects facial challenges to state prohibitions on assault weapons and large-capacity magazines at text step of Bruen-Rahimi framework; also rejects facial challenge to California’s firearm licensing scheme in effect at time of defendant’s offense

Prohibited Persons

1. United States v. Minor, --- F.4th ----, 2026 WL 205527 (1st Cir. Jan. 27, 2026): First Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(g)(9) (misdemeanor crime of domestic violence prohibitor) at history step of Bruen-Rahimi framework, based on the same historical tradition recognized in Rahimi of “restrict[ing] gun use to mitigate demonstrated threats of physical violence”
2. United States v. Hembree, --- F.4th ----, 2026 WL 217125 (5th Cir. Jan. 27, 2026): Fifth Circuit holds 18 U.S.C. § 922(g)(1) (federal felony prohibitor) unconstitutional as applied to defendant with predicate conviction for possession of methamphetamine, finding that “the government did not meet its burden to prove that history and tradition support simple possession as a valid felony predicate”; in a concurrence, Judge Willett again states openness to reconsidering circuit precedent on Commerce Clause issue
3. Andrew v. Adorno, 348 A.3d 805 (R.I. 2026): Rhode Island Supreme Court rejects lower court’s ruling that a clear-and-convicing-evidence standard of proof is required in civil protective-order proceedings “when a defendant’s rights under the Second Amendment … would be temporarily restricted” and remands for a new hearing applying a preponderance-of-the-evidence standard