Second Amendment Update: What’s Changing After New York State Rifle & Pistol Assn., Inc. v. Bruen?

By Robert Phillips, Deputy District Attorney (Ret).

Second Amendment Update: What’s new under New York State Rifle & Pistol Assn., Inc. v. Bruen, the Second Amendment, and the regulation of firearms  

Since the U.S. Supreme Court’s landmark decision of New York State Rifle & Pistol Assn., Inc. v. Bruen (June 23, 2022) 597 U.S. ___ [213 L. Ed.2nd 387; 142 S.Ct. 2111], setting out the standards to be used in evaluating the constitutionality of every state’s Second Amendment statutes, we’ve been receiving from the appellate courts a case-by-case reevaluation of California’s restrictions on the owning and carrying of firearms. 

In a nutshell, Bruen had the effect of striking down statutes in six states: California, New York, Hawaii, Maryland, Massachusetts and New Jersey, and the District of Columbia, each of which imposed a “proper cause” requirement for a citizen to obtain a permit to carry a concealed firearm in public.  

California’s requirement was worded a bit differently, requiring “good cause.” The California attorney general has conceded, however, that the difference in wording is irrelevant; that the two phrases mean the same thing. (E.g., In re D.L., infra, at pg. 148.) The attorney general has similarly conceded (without any specific case ....

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