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Recent Decisions

Earlier Decisions

      Below are previous updates from our recent decisions page, organized by date posted.

      January 9, 2026

      Open Carry

      1. Baird v. Bonta, --- F.4th ----, 2026 WL 17404 (9th Cir. Jan. 2, 2026): Divided Ninth Circuit panel holds California’s prohibition on open carry of firearms in counties with populations over 200,000 unconstitutional, creating acknowledged conflict with the Second Circuit; Judge N.R. Smith dissents, explaining that majority’s decision “def[ies] Bruen” and that challenged law is constitutional at both text and history steps of Bruen–Rahimi framework; panel also unanimously finds that plaintiffs waived their as-applied challenge to California’s licensing requirements for open carry in counties with populations under 200,000, and that their facial challenge to these requirements fails on the merits

      Licensing

      1. McGregor v. Suffolk County, No. 2:23-cv-01130, 2025 WL 3704289 (E.D.N.Y. Dec. 22, 2025): rejects challenge to New York’s licensing and registration law for semiautomatic rifles at history step of Bruen–Rahimi framework, concluding that the laws’s “licensing, registration, and moral character requirements fit comfortably within three hundred years of state firearm regulations”

      Restricted Weapons and Accessories

      1. United States v. Kittson, 161 F.4th 619 (9th Cir. 2025): Ninth Circuit rejects challenge to 18 U.S.C. § 922(o) (federal restriction on machinegun transfer or possession) under pre-Bruen circuit precedent, holding that “machine guns are ‘dangerous and unusual weapons’ that are unprotected by the Second Amendment”; Judge Van Dyke dissents on statutory grounds and “would not reach the Second Amendment question”
      2. United States v. Peterson, 161 F.4th 331 (5th Cir. 2025): Fifth Circuit withdraws prior opinion and issues near-identical substitute opinion again rejecting as-applied challenge to National Firearms Act’s restriction on silencers; rehearing en banc also denied
      3. People v. Crenshaw, --- Cal. Rptr. 3d ----, 2025 WL 3563413 (Ct. App. Dec. 12, 2025): California intermediate appellate court upholds state law prohibiting assault weapons, ruling that the prohibition “is beyond the scope of the Second Amendment because it has not been shown that such weapons are in common use by law-abiding citizens”; decision accords with “unanimous precedent” of California state courts

      Prohibited Persons

      1. United States v. Gould, --- F.4th ----, 2026 WL 18823 (4th Cir. Jan. 2, 2026): Fourth Circuit holds 18 U.S.C. § 922(g)(4) (federal mental-health prohibitor) facially constitutional at history step of Bruen-Rahimi framework, finding “an unambiguous history and tradition of disarming and incarcerating those whose illness made them a danger to themselves or others”
      2. United States v. Vazquez-Ramirez, --- F.4th ----, 2026 WL 17253 (9th Cir. Jan. 2, 2026) (per curiam): Ninth Circuit rejects as-applied challenge to 18 U.S.C. § 922(g)(5)(A) (prohibition on firearm possession by undocumented immigrants) at history step of Bruen–Rahimi framework; Judge Butamay concurs in the judgment, arguing that the challenge should fail at the text step because “illegal aliens are not among ‘the people’ the Second Amendment protects”
      3. United States v. Cockerham, --- F.4th ----, 2025 WL 3653336 (5th Cir. Dec. 17, 2025): Fifth Circuit holds 18 U.S.C. § 922(g)(1) (federal felony prohibitor) unconstitutional as applied to defendant with a prior conviction for failure to pay child support; Judge Ho, author of the majority opinion, also separately concurs “to defend [the Fifth Circuit]’s earlier decision in Rahimi,” which the Supreme Court reversed, “as a faithful application of [Bruen]”; Judge Higginson dissents, stating he would remand for further development of the historical record
      4. United States v. Duque-Ramirez, 161 F.4th 1237 (10th Cir. 2025): Tenth Circuit rejects as-applied challenge to 18 U.S.C. § 922(g)(5)(A) (prohibition on firearm possession by undocumented immigrants) at history step of Bruen–Rahimi framework
      5. United States v. Escobar-Temal, 161 F.4th 969 (6th Cir. 2025): Sixth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(g)(5)(A) (prohibition on firearm possession by undocumented immigrants) at history step of Bruen–Rahimi framework, while also holding that defendant has “sufficient connections to the national community” to make him part of “the people” referenced in the Second Amendment’s text; Judge Thapar dissents in part and concurs in the judgment, disagreeing with the majority and concluding that “the people” protected by the Second Amendment includes only U.S. citizens 

      Sensitive Places

      1. Koons v. Attorney General New Jersey, 162 F.4th 100 (3d Cir. 2025) (en banc): Third Circuit vacates panel opinion that had upheld almost all of New Jersey’s restrictions on firearms in sensitive places and orders rehearing en banc
      2. United States v. Williams, No. 6:25-cr-00015, 2025 WL 3610039 (D. Mont. Dec. 12, 2025): rejects as-applied challenge to federal Gun-Free School Zones Act (18 U.S.C. § 922(q)(2)(A)) at history step of Bruen–Rahimi framework; distinguishes recent Ninth Circuit decision in United States v.Metcalf, 156 F.4th 871 (9th Cir. 2025), which had dismissed indictment of a different Montana defendant under the Act on statutory grounds, as “narrow and limited to its unique circumstances”

      Age Restrictions

      1. State v. Matosky, No. 30447, 2025 WL 3687998 (Ohio Ct. App. 2d Dist. Dec. 19, 2025): Ohio intermediate appellate court in one appellate district holds state laws prohibiting individuals under 21 from (a) carrying a concealed handgun or (b) having an accessible, loaded firearm in a motor vehicle unconstitutional as applied to 20-year-old defendant
      2. State v. Baxter, No. C-240555, 2025 WL 3720652 (Ohio Ct. App. 1st Dist. Dec. 23, 2025): Ohio intermediate appellate court in a different appellate district upholds constitutionality of same state age-restriction laws held unconstitutional in State v. Matosky

      December 8, 2025

      Prohibited Persons

      1. United States v. Mitchell, --- F.4th ----, 2025 WL 3251467 (5th Cir. Nov. 21, 2025): Fifth Circuit holds 18 U.S.C. § 922(g)(1) (federal felony prohibitor) unconstitutional as applied to defendant with a prior § 922(g)(3) conviction for unlawfully possessing a firearm as a marijuana user; Judge Haynes dissents, and “at a minimum” would have held the case pending the Supreme Court’s decision in United States v. Hemani
      2. United States v. Bonner, --- F.4th ----, 2025 WL 3191964 (5th Cir. Nov. 13, 2025): Fifth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(g)(1) (federal felony prohibitor) under circuit precedent; concurring opinion by Judge Willett, joined by Judge Duncan, questions aspects of the circuit’s current Second Amendment and Commerce Clause jurisprudence
      3. State v. McCray, --- P.3d ----, 2025 WL 3181050 (Kan. Nov. 14, 2025): Kansas Supreme Court upholds state law prohibiting gun possession by individuals with a misdemeanor domestic violence conviction in the last five years at history step of Bruen-Rahimi analysis

      Restricted Weapons

      1. United States v. Charles, --- F.4th ----, 2025 WL 3239061 (8th Cir. Nov. 20, 2025): Eighth Circuit rejects facial challenge to 18 U.S.C. § 922(o) (federal restriction on machine gun possession) at text step of Bruen–Rahimi analysis, finding that “[b]ecause there are machine guns… that are not bearable weapons, the regulation of at least those weapons is consistent with the Second Amendment”; one judge concurred in judgment 
      2. United States v. Hernandez, --- F.4th ----, 2025 WL 3236975 (5th Cir. Nov. 20, 2025): Fifth Circuit rejects as-applied challenge to federal law prohibiting possession of an unregistered short-barreled shotgun; also rejects challenge to § 922(g)(1) 
      3. United States v. Gomez, --- F.4th ----, 2025 WL 3199468 (2d Cir. Nov. 17, 2025): Second Circuit rejects facial challenge to 18 U.S.C. § 922(k) (prohibition on possessing a firearm with an obliterated serial number) at text step of Bruen-Rahimi analysis “because (i) no person is thereby prevented from possessing any type of firearm, and (ii) a firearm with a removed, obliterated, or altered serial number is not a weapon in common use for lawful purposes”

      Background Checks and Licensing

      1. Rhode v. Bonta, --- F.4th ----, 2025 WL 3441686 (9th Cir. Dec. 1, 2025): Ninth Circuit vacates panel opinion that had held California’s law requiring background checks for ammunition sales facially unconstitutional and orders rehearing en banc
      2. People v. Johnson, --- N.E.3d ----, 2025 WL 3259873 (N.Y. Nov. 24, 2025): New York Court of Appeals rejects facial challenge to the state’s entire firearms licensing scheme, concluding that the “proper cause” requirement Bruen invalidated is severable, and “[t]he defendant has failed to show that there is no set of circumstances in which the licensing scheme would be constitutionally valid”

      November 11, 2025

      Prohibited Persons

      1. United States v. VanDyke, --- F.4th ----, 2025 WL 3000188 (9th Cir. Oct. 27, 2025): Ninth Circuit rejects as-applied challenge to 922(g)(8)(C)(ii) (federal prohibition on gun possession by those subject to certain domestic violence restraining orders) at history step of Bruen–Rahimi framework “under the historical traditions of individual disarmament and categorical disarmament” 
      2. United States v. Oghenebrume, No. 3:25-cr-00068, 2025 WL 2977055 (M.D. La. Oct. 21, 2025): rejects facial and as-applied challenges to 18 U.S.C. § 922(g)(5)(B) (prohibition on firearm possession by nonimmigrant visa holders) at history step of Bruen–Rahimi framework
      3. State v. Riffee, No. C-240535, 2025 WL 2993210 (Ohio Ct. App. Oct. 24, 2025): Ohio intermediate appellate court upholds state law prohibiting the carry or use of firearms “while under the influence of alcohol or any drug of abuse” as applied to defendant carrying a handgun in his home while intoxicated at history step of Bruen–Rahimi framework; also rejects challenge under Ohio Constitution

      Age Restrictions

      1. State v. Stonewall, No. C-240607, 2025 WL 3046561 (Ohio Ct. App. Oct. 31, 2025): Ohio intermediate appellate court affirms convictions of 19-year-old defendant under state statutes prohibiting those under 21 from carrying concealed weapons and having a loaded firearm in a motor vehicle at history step of Bruen–Rahimi framework
      2. State v. Walkes, No. 25003340CF10A, 2025 LX 474699 (Fla. Cir. Ct. Oct. 24, 2025): Florida trial court holds that state prohibition on concealed carry by 18-to-20 year olds violates Second Amendment as applied to 19-year-old defendant  
      3. Wilson v. Hanley, No. CL20000582 (Va. Cir. Ct. Oct. 16, 2025): Virginia trial court orders permanent injunction of state law requiring background checks for all firearm transactions, following its 2020 and 2024 rulings that the statute is unconstitutional under the Virginia Constitution “as-applied to those 18 to 20 years of age,” holding that the law “must be stricken in its entirety” as remedy
        • On October 29, 2025, the court entered its final order and permanent injunction

      October 21, 2025

      Background Checks

      1. New York State Firearms Ass’n v. James, --- F.4th ----, 2025 WL 2921746 (2d Cir. Oct. 15, 2025): Second Circuit rejects challenge to New York’s ammunition background check provisions at text step of Bruen-Rahimi framework, finding that “none of the challenged provisions—individually or collectively—meaningfully constrain an individual’s right to ‘keep’ and ‘bear’ arms”

      Sensitive Places

      1. Springer v. Lujan Grisham, Nos. 23-2192, 23-2194, 2025 WL 2793787 (10th Cir. Oct. 1, 2025) (unpublished): Tenth Circuit rejects, for lack of standing, facial challenge to New Mexico public health order prohibiting firearms in public parks and playgrounds in Albuquerque and surrounding county
      2. Nastri v. Dykes, No. 3:23-cv-00056, 2025 WL 2884945 (D. Conn. Sept. 30, 2025): rejects facial and as-applied challenges to Connecticut prohibition on carrying handguns in state parks and forests at history step of Bruen-Rahimi framework, holding that the “the prohibition is within the well-established tradition and history of regulating firearms in sensitive places due to their quintessentially crowded nature and the fact that they are frequented by children”
      3. Firearms Policy Coalition v. Bondi, No. 4:24-cv-00565, 2025 WL 2783113 (N.D. Tex. Sept. 30, 2025): grants summary judgment to plaintiffs challenging federal prohibition on carrying firearms in an “ordinary” post office or on postal property

      Restricted Weapons and Accessories

      1. United States v. Taylor, No. 24-4392, 2025 WL 2784820 (4th Cir. Sept. 30, 2025) (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 under Heller and circuit precedent
      2. Montgomery v. Rosenblum, No. 3:24-cv-01273, 2025 WL 2781758 (D. Or. Sept. 29, 2025): dismisses challenge to Oregon’s “ghost gun” law, which prohibits the sale, manufacture, and possession of “undetectable firearms, unserialized firearms, and unserialized unfinished firearm frames and receivers,” for failure to state a claim, finding that “[p]laintiffs do not sufficiently allege that [the law] concerns firearms commonly in use by ‘law-abiding citizens with ordinary self-defense needs’”
      3. State v. Bibbs, --- P.3d ----, 2025 WL 2694417 (Haw. App. Sept. 22, 2025): Hawai‘i intermediate appellate court upholds state law prohibiting the possession of large-capacity magazines at text step of Bruen-Rahimi framework, concluding that challenger “ha[d] failed to establish that an LCM is an ‘arm’ within the meaning of the Second Amendment or a protected accessory”

      Other Restrictions

      1. Elite Precision Customs LLC v. Bureau of Alcohol, Tobacco, Firearms & Explosives, No. 4:25-cv-00044, 2025 WL 2778498 (N.D. Tex. Sept. 30, 2025): upholds federal restrictions on the interstate sale of firearms at text step of Bruen-Rahimi framework
      2. Gazzola v. Hochul, No. 1:22-cv-1134, 2025 WL 2771835 (N.D.N.Y. Sept. 26, 2025): among other holdings in challenge to multiple firearms restrictions, rejects challenge to New York regulations on firearm dealers’ operations for lack of basis to infer that regulations “impair citizens’ access to firearms or ammunition”  

      September 30, 2025

      Sensitive Places, Licensing, and Public Carry

      1. Frey v. City of New York, 157 F.4th 118 (2d Cir. 2025): Second Circuit upholds New York’s laws prohibiting the open carry of firearms, prohibiting firearms in Times Square and on the subway and commuter trains, and requiring a city-specific permit to carry a firearm in New York City
      2. Koons v. Attorney General New Jersey, 156 F. 4th 210 (3d Cir. 2025): Third Circuit upholds almost all of New Jersey’s law prohibiting guns in sensitive places, including in parks, playgrounds, bars and restaurants that serve alcohol, stadiums, and on public transit; affirms preliminary injunction as to restrictions on carrying firearms in private vehicles and on private property open to the public; also rules on aspects of New Jersey’s permitting and insurance requirements for public carry
        • On December 11, 2025, the Third Circuit vacated the panel opinion and ordered the case be reheard en banc
      3. Giambalvo v. Suffolk County, 155 F.4th 163 (2d Cir. 2025): Second Circuit rejects facial challenges to (a) several provisions of New York’s firearm licensing regime, including good moral character, in-person interview, character reference, and firearms training requirements and (b) Suffolk County’s licensing processing timeline, “which allegedly can take up to several years” 
      4. Russell v. District of Columbia, No. CV 24-1820 (JDB), 2025 WL 2719342 (D.D.C. Sept. 24, 2025): upholds D.C. regulation requiring concealed-carry licensees to carry their firearms holstered on their person (as opposed to “off-body carry,” e.g., in a bag) at history step of Bruen-Rahimi framework
      5. Johnson v. Jacobson, No. 0:25-cv-00054, 2025 WL 2624380 (D. Minn. Sept. 11, 2025): rejects facial challenge to Minnesota law that limits public carry to individuals with a Minnesota permit or a permit from one of the 33 states to which Minnesota currently grants reciprocity at history step of Bruen-Rahimi framework 
      6. McDaniels v. State, --- So.3d ----, 2025 WL 2608688 (Fla. Dist. Ct. App. Sept. 10, 2025): Florida intermediate appellate court declares state law prohibiting open carry of firearms unconstitutional at history step of Bruen-Rahimi framework
        • On September 15, 2025, the Florida Attorney General issued guidance to law enforcement and prosecutors that “[b]ecause no other [Florida] appellate court has considered the constitutionality of [the open-carry law] under Bruen and Rahimi, [McDaniels] is binding on all Florida’s trial courts”

      Age Restrictions

      1. Picon v. United States, 343 A.3d 57 (D.C. 2025): D.C.’s highest court upholds the District’s restrictions on firearm possession and carry by individuals under 21 at history step of Bruen-Rahimi framework, finding that historical tradition of forbidding purchase of firearms by those under age 21 is relevantly similar to D.C.’s law 

      Prohibited Persons

      1. United States v. Ogilvie, 153 F.4th 1098 (10th Cir. 2025): Tenth Circuit rejects facial challenge to 18 U.S.C. § 922(n) (prohibiting people under indictment from acquiring firearms) at history step of Bruen-Rahimi framework, holding that the law is “‘relevantly similar’ to pretrial detention and bail at the founding”
      2. Browne v. Reynolds, 150 F.4th 975 (8th Cir. 2025): Eighth Circuit rejects as-applied challenge to Iowa statute providing that an individual convicted  of a “forcible felony” (e.g., murder, assault, sexual abuse, kidnapping, robbery) is ineligible for restoration of firearms rights, concluding that a lifetime restriction, subject only to a gubernatorial pardon, is “consistent with the Nation’s historical tradition of firearms regulation”

      Restricted Accessories

      1. Morse v. Raoul, Nos. 3:22-cv-02740, 3:23-cv-00728, 2025 WL 2576434 (S.D. Ill. Sept. 5, 2025): rejects challenge to Illinois’s law prohibiting the possession of silencers, concluding that plaintiffs have failed to demonstrate that “silencers are ‘arms’ as that term was understood in the eighteenth century”

      September 4, 2025

      Sensitive Places

      1. LaFave v. County of Fairfax, 149 F.4th 476 (4th Cir. 2025): Fourth Circuit rejects Second Amendment challenge to Fairfax County, Virginia ordinance prohibiting guns in county parks, holding that the prohibition is constitutional as applied to the four preschools on park property, and that is sufficient to reject plaintiffs’ facial challenge; also holds that plaintiffs lacked standing to challenge prohibition on guns at or near county-permitted events 
      2. Schoenthal v. Raoul, 150 F.4th 889 (7th Cir. 2025): Seventh Circuit rejects challenge to Illinois law prohibiting guns on public transit at history step of Bruen-Rahimi framework, holding that the restriction “is comfortably situated in a centuries-old practice of limiting firearms in sensitive and crowded, confined places”

      Assault Weapons and Large-Capacity Magazines

      1. National Ass’n for Gun Rights v. Lamont, 153 F.4th 213 (2d Cir. 2025): Second Circuit rejects challenge to Connecticut laws restricting assault weapons and large-capacity magazines at history step of Bruen-Rahimi framework, holding that laws are consistent with the “historical tradition of regulating unusually dangerous weapons”; also concludes that plaintiffs failed to establish non-merits requirements for preliminary injunction

      Other Restricted Weapons and Accessories

      1. United States v. Morgan, 150 F.4th 1339 (10th Cir. 2025): Tenth Circuit rejects as-applied challenge to 18 U.S.C. § 922(o) (federal restriction on machine gun possession) at text step of Bruen–Rahimi framework
      2. United States v. Peterson, 150 F.4th 644 (5th Cir. 2025): Fifth Circuit rejects as-applied challenge to National Firearms Act’s restriction on silencers

      Prohibited Persons

      1. United States v. Harrison, 153 F.4th 998 (10th Cir. 2025): Tenth Circuit reverses dismissal of indictment in as-applied challenge to 18 U.S.C. § 922(g)(3) (prohibition on firearm possession by unlawful drug users) brought by non-intoxicated marijuana users, holding that “historical tradition supports a principle that legislatures may disarm those believed to pose a risk of future danger”
      2. Florida Commissioner of Agriculture v. Attorney General, 148 F.4th 1307 (11th Cir. 2025): Eleventh Circuit vacates dismissal of as-applied challenge to 18 U.S.C. § 922(d)(3) and (g)(3) (prohibition on firearm sale to and possession by unlawful drug users) brought by medical marijuana users, holding that federal government failed, at motion-to-dismiss stage, to meet its burden at history step of Bruen–Rahimi framework   
      3. United States v. Murillo-Lopez, 151 F.4th 584 (4th Cir. 2025): Fourth Circuit rejects challenge to 18 U.S.C. § 922(g)(5)(A) (prohibition on firearm possession by undocumented immigrants) under controlling pre-Bruen precedent

      Age Restrictions

      1. Birney v. Delaware Department of Safety & Homeland Security, --- A.3d ----, 2025 WL 2489468 (Del. Super. Ct. Aug. 29, 2025): holds state law restricting the purchase and possession of certain firearms by 18-to-20-year-olds violates the Delaware Constitution, applying intermediate scrutiny

      Other Restrictions

      1. Ortega v. Lujan Grisham, 148 F.4th 1134 (10th Cir. 2025): Tenth Circuit holds New Mexico’s seven-day waiting period law unconstitutional; Judge Matheson dissents, explaining that the law should be upheld under controlling circuit precedent because it “establishes a condition or qualification on the commercial sale of arms that does not serve abusive ends”
        • On September 2, 2025, State filed petition for rehearing en banc
      2. United States v. Vereen, 152 F.4th 89 (2d Cir. 2025): Second Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(a)(3) (federal restriction on interstate transfer of firearms) at both text and history steps of Bruen–Rahimi framework
      3. Granata v. Campbell, No. 21-cv-10960 , 2025 WL 2495956 (D. Mass. Aug. 29, 2025): holds Massachusetts handgun safety requirements constitutional at text and history steps of Bruen-Rahimi framework

      August 12, 2025

      Prohibited Persons

      1. United States v. Simmons, 150 F.4th 126 (2d Cir. 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, 150 F.4th 552 (6th Cir. 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, 147 F.4th 522 (5th Cir. 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, 146 F.4th 421 (4th Cir. 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, 144 F.4th 1119 (9th Cir. 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, 150 F.4th 517 (6th Cir. 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, 25 N.W.3d 732 (Minn. Ct. App. 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

      July 24, 2025

      Background Checks and Licensing

      1. Rhode v. Bonta, 145 F.4th 1090 (9th Cir. 2025): Ninth Circuit panel holds that California’s law requiring background checks for ammunition sales is facially unconstitutional. Judge Bybee dissents, explaining that law does not “meaningfully constrain” the right and is also a “presumptively lawful” regulatory measure, and should therefore be upheld
        • On December 1, 2025, the Ninth Circuit vacated the panel opinion and ordered the case be reheard en banc
      2. United States v. Vlha, 142 F.4th 1194 (9th Cir. 2025): Ninth Circuit rejects facial and as-applied challenges to 18 U.S.C. § 922(a)(1)(A) (prohibition on conspiring to manufacture firearms for sale without a federal license) and 18 U.S.C. § 922(d)(1) (prohibition on selling a firearm to a felon) at text step of Bruen–Rahimi analysis, applying the “ancillary-rights doctrine” and concluding that neither law “‘meaningfully constrain[s]’ the core individual possessory right”     
      3. State v. Tavarez-Rodriguez, No. A-0713-03, 2025 WL 1922334 (N.J. Super. Ct. App. Div. July 14, 2025) (per curiam) (unpublished): New Jersey intermediate appellate court holds that New Jersey is not required to recognize out-of-state licenses to carry firearms, rejecting Second Amendment and Full Faith and Credit Clause challenges to prosecution for unlawful handgun possession by an individual licensed to carry in Pennsylvania but not in New Jersey

      Prohibited Persons

      1. United States v. Carbajal-Flores, 143 F.4th 877 (7th Cir. 2025): Seventh Circuit rejects facial and as-applied Second Amendment challenges to 18 U.S.C. § 922(g)(5)(A) (prohibition on firearm possession by undocumented immigrants) at history step of Bruen–Rahimi analysis
      2. United States v. Harris, 144 F.4th 154 (3d Cir. 2025): Third Circuit holds that 18 U.S.C. § 922(g)(3) (prohibition on firearm possession by unlawful drug users) does not violate Second Amendment as applied to “those who pose a special danger of misusing firearms because they frequently use drugs” and remands for factual findings as to defendant; also rejects facial vagueness challenge to 18 U.S.C. § 922(g)(3) and affirms conviction under 18 U.S.C. § 922(a)(6) (re false statements)
      3. United States v. Cordoza Perez, 145 F.4th 800 (8th Cir. 2025): Eighth Circuit vacates defendant’s conviction under 18 U.S.C. § 922(g)(3) and remands for district court to reassess as-applied Second Amendment challenge 
      4. Dorrance v. Bondi, No. 1:25-cv-00040 (D. Wyo. July 22, 2025): federal district court rejects Second Amendment challenge to 18 U.S.C. § 922(g)(7) (prohibition on firearm possession by persons who renounce U.S. citizenship) at history step of Bruen–Rahimi analysis; also rejects equal protection claim  

      Storage

      1. Commonwealth v. McMickle, No. 2481-cr-00232, 2025 WL 2018552 (Mass. Super. Ct. July 16, 2025): Massachusetts trial court rejects Second Amendment challenge to firearm storage statute at text step of Bruen–Rahimi analysis

      July 8, 2025

      Age Restrictions

      1. McCoy v. Bureau of Alcohol, Tobacco, Firearms & Explosives, 140 F.4th 568 (4th Cir. 2025), petition for cert. filed, No. 25-24 (July 3, 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
      2. Commonwealth v. Williams, 341 A.3d 144 (Pa. Super. Ct. 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, 789 F.Supp.3d 995 (S.D. Cal. 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, 142 F.4th 308 (5th Cir. 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, 23 N.W.3d 258 (Iowa 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, 23 N.W.3d 231 (Iowa 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, 140 F.4th 1237 (9th Cir. 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, 340 A.3d 977 (Pa. Super. Ct. 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

      June 13, 2025

      Prohibited Persons

      1. Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025): Second Circuit holds 18 U.S.C. § 922(g)(1) (federal felony prohibitor) constitutional on its face and as applied to both violent and nonviolent felons, concluding that “Congress has the authority to disarm all felons” as a class in accordance with the Second Amendment, “without need to find individual present dangerousness”; also rejects procedural due process challenge
      2. United States v. Betancourt, 139 F.4th 480 (5th Cir. 2025): Fifth Circuit rejects as-applied Second Amendment challenge to 18 U.S.C. § 922(g)(1) in the case of a criminal defendant with prior convictions for aggravated assault arising from a car crash he caused
      3. United States v. Dubois, 139 F.4th 887 (11th Cir. 2025): After GVR in light of Rahimi, Eleventh Circuit reaffirms constitutionality of 18 U.S.C. § 922(g)(1) based on its prior, pre-Bruen circuit precedent
        • Chief Judge Pryor, joined by Judge Rosenbaum, concurs to explain that he would likely uphold the law under Bruen-Rahimi analysis, even if not bound by prior circuit precedent
      4. United States v. Jackson, 138 F.4th 1244 (10th Cir. 2025): Tenth Circuit rejects facial Second Amendment challenge to 18 U.S.C. § 922(g)(9) (misdemeanor crime of domestic violence prohibitor)
      5. Fooks v. State, 337 A.3d 83 (Md. 2025): Maryland Supreme Court holds Maryland’s state felony/felony-equivalent prohibitor law constitutional under Second Amendment on its face and as applied to both violent and nonviolent offenses

      Assault Weapons and Large-Capacity Magazines

      1. Hanson v. District of Columbia, 145 S. Ct. 2778 (2025): Supreme Court denies petition for certiorari from Hanson v. District of Columbia, 120 F.4th 223 (D.C. Cir. 2024), D.C. Circuit decision rejecting Second Amendment challenge to D.C.’s law restricting large-capacity magazines 
      2. Snope v. Brown, 145 S. Ct. 1534 (2025): Supreme Court denies petition for certiorari from Bianchi v. Brown, 111 F.4th 438 (4th Cir. 2024), en banc Fourth Circuit decision upholding Maryland’s law restricting assault weapons
        • Justices Thomas, Alito, and Gorsuch would have granted the petition; Justice Thomas dissented from the denial of certiorari; Justice Kavanaugh issued a statement respecting the denial of certiorari
      3. Ocean State Tactical v. Rhode Island, 145 S. Ct. 2771 (2025): Supreme Court denies petition for certiorari from Ocean State Tactical, LLC v. Rhode Island, 95 F.4th 38 (1st Cir. 2024), First Circuit decision rejecting Second Amendment challenge to Rhode Island’s law restricting assault weapons
        • Justices Thomas, Alito, and Gorsuch would have granted the petition
      4. Viramontes v. Cook County, No. 24-1437, 2025 WL 1553896 (7th Cir. June 2, 2025) (nonprecedential): Seventh Circuit affirms grant of summary judgment to Cook County, Illinois in challenge to local ordinance restricting assault weapons

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      Did you know?

      30 percent of guns recovered by ATF in California have no serial number on them, making it impossible for law enforcement to trace.

      Stephens A. “Ghost Guns Are Everywhere in California”. The Trace. (2019). https://bit.ly/2DKkIlt