New York State Rifle & Pistol Assn., Inc. v. Bruen

The Second Amendment prohibits states from preventing law-abiding citizens from carrying a firearm in public because they had not demonstrated a need for self-defense.

New York State prohibited individuals from possessing firearms without a license inside and outside of their homes unless they have “proper cause,” which required special need for self-defense. Petitioners sued Respondents, alleging that their Second and Fourteenth Amendment rights were violated after their unrestricted license applications were denied for failing to show proper cause. The District Court dismissed Petitioner's complaint and the Court of Appeals affirmed. The Supreme Court reversed, holding that New York’s proper cause requirement violates the Fourteenth Amendment because it prevents law-abiding citizens with self-defense needs from exercising their Second Amendment rights. Furthermore, the test in District of Columbia v. Heller requires courts to assess whether firearms regulations are consistent with the Amendment’s text and history by evaluating (1) whether firearms regulations impose a burden on the right of armed self-defense and (2) whether that burden is justified. Nothing in the Amendment’s text draws a distinction between bearing and carrying arms at home and in public. The Court also determined that Respondents failed to demonstrate that New York’s proper cause requirement is consistent with the Nation’s history, traditions, and how the Framers envisioned the Amendment’s applicability at the time of the founding. The right to bear arms in public for self-defense, like other constitutional rights, should not require a showing of special need. Reversed and remanded.