A Surprise Amicus Brief in the Challenge to New York’s Gun Carry Ban – Reason
New York has received support from an unlikely source in defense of its restrictive public carry laws in the form of an amicus brief filed in NYSRPA v. Bruen, the Supreme Court case that will decide whether the Second Amendment protects a right to carry firearms in public for self-defense. The brief was submitted on behalf of several signatories, but most noteworthy is its headlinerJ. Michael Luttig, the former Fourth Circuit judge who reportedly was on the shortlist for nomination to a Supreme Court seat during the George W. Bush administration. The brief does not live up to the standards one would expect from Judge Luttig.
First and foremost, while claiming to take a "textualist" approach (at 7), the brief fails to confront the Second Amendment's clear statement that the right of "the people" to "bear" arms shall not be infringed. New York absolutely criminalizes the bearing of arms openly and issues licenses to carry arms concealed only to a selected few who the state deems to have "proper cause." Instead of bearing arms being the rule while carving out exceptions (such as for courthouses and legislatures), the brief argues that the right is not infringed because narrow exceptions are made for hunting and target practice (at 6). But that ignores that "self-defense was the central component of the right itself," Heller, 554 U.S. at 599.
The brief's shortcomings are conspicuous in its engagement with history. The brief purports to apply Heller's text, history, and tradition approach, averring that "founding-era statutes" are particularly important (at 1011). Yet the brief cites a grand total of six colonial and early state laws to support its remarkable assertion that the founding era did not understand the right to carry to extend to the public. The brief's authors ignore the extensive evidence refuting their argumentsmuch of it in amicus briefs previously filed in support of the plaintiffs. Nor does the brief address the dismissal by Justice Thomas of such arguments based on the Statute of Northampton and its state analogues articulated in his dissent from the denial of certiorari in Rogers v. Grewal, 140 S. Ct. 1865 (2020), arising out of New Jersey. All of the material historical issues here are covered in my book, The Right to Bear Arms: A Constitutional Right of the People or a Privilege of the Ruling Class? Pay special attention to the Forward by Rene Lettow Lerner, which traces the modern anti-Second Amendment campaign back to 1968.
Embarrassingly, the brief relies (at 12) on a 1792 North Carolina "law" purportedly providing that no person may "go nor ride armed by night or by day, in fairs, markets, nor in the presence of the King's Justices, or other ministers, nor in no parts elsewhere." It should have been obvious that something is amisswhy would a 1792 North Carolina statute refer to the King? The reason is there was no such statutethe cited law "is fake," the source being a compilation of North Carolina laws that later compilers condemned as including many statutes "which never were, and never could have been in force." See my book The Right To Bear Arms at 243 n.778.
While the other five statutes (3 colonial and 2 state) were actually enacted, they do not demonstrate that founding-era legislatures felt themselves free to ban public carry. Four of the statutes plainly are analogues of the 1328 Statute of Northamptona statute with a lengthy history of interpretation with which the brief fails entirely to engage. (See my post on Tuesday.) And by the time of the founding, the historical sources indicate that the Statute and its analogues barred only carrying dangerous and unusual weapons or in a manner otherwise calculated to induce terror. This is apparent from the words of the statutes themselves, which as quoted in the Luttig brief (at 1213) focus on carrying "offensively" (1699 N.H.) and inducing "fear" (1692 and 1795 Mass.) or "terror" (1786 Va.).
That leaves only an obscure 1686 East New Jersey law (the colony was then split into East and West) that prohibited the private carry of "pocket pistols" and provided that "no planter shall ride or go armed with sword, pistol or dagger." The latter part may have only applied to terror-inducing carry, as otherwise the former part would be redundant. We don't know if the law survived the English Declaration of Rights of 1689, which declared the right to have arms, but it was long since forgotten when the Second Amendment was ratified. Indeed, the public carrying of firearms was legal in the State of New Jersey until 1966. See generally The Right to Bear Arms at 123-31. Regardless, Heller refused to "stake [its] interpretation of the Second Amendment upon a single law, in effect in a single city, that contradicts the overwhelming weight of other evidence regarding the right to keep and bear arms for defense of the home." 554 U.S. at 632.
The Luttig brief fails to discuss the wealth of evidence demonstrating that Americans at the founding understood the right to bear arms to extend to public carry. For example, as an amicus brief filed by the Second Amendment Foundation demonstrates, our first six Presidents and other leading Founders were proponents and practitioners of arms bearing. Some were citizens of Virginia or Massachusetts, two states which according to the Luttig brief barred public carry altogether. That would have been a surprise to the likes of Jefferson and Adams, who under the Luttig brief's conception of history would have been serial lawbreakers.
Once history is understood as demonstrating a right to public carry, the Luttig brief becomes self-refuting. With its historical case collapsing, it is left with the sorts of policy arguments that the brief indicates should not be used to determine constitutional rights. And some of those arguments are bizarre. For example, the brief refers to the incursion of protestors into the Capitol on January 6, seeming to argue that such events would become more frequent and deadlier were a right to public carry to be recognized. But D.C. itself already is a right-to-carry jurisdiction, with the D.C. Circuit in Wrenn v. D.C., 864 F.3d 650 (2017), having struck down a may-issue law akin to the current New York law.
The brief ignores the history laid out in the amicus brief of the Independent Institute that demonstrates that there were restrictions at the time of the founding on carrying firearms into courts and legislative bodies. The brief also fails to engage with the literature reviews concluding that based on existing empirical evidence it cannot be said that respecting the right to carry leads to increased crime and violence.
More criticisms of the brief could be made, from misciting then-Judge Barrett's opinion in Kanter v. Barr, 919 F.3d 437, 451 (7thCir. 2019), as concurring rather than dissenting (at 2 & 11) to its amateurish lack of background on the history of the Second Amendment. The Luttig brief is not to be taken seriously as a work of historical scholarship. If it weren't for the identity of its lead sponsor, it is doubtful anyone would give it a second look, and its arguments should play no role in the Supreme Court's decision.
See the article here:
A Surprise Amicus Brief in the Challenge to New York's Gun Carry Ban - Reason
- "Bans Don't Work": Second Amendment Group Responds to Latest Recommendations from Gov. Whitmer's Task Force - WHMI - November 28th, 2025 [November 28th, 2025]
- DOJ to Launch Second Amendment Rights Office on Dec. 4th - USA Carry - November 28th, 2025 [November 28th, 2025]
- GOA & GOF Declare DOJ Brief an Open Attack on the Second Amendment and the Constitution - Gun Owners of America - November 28th, 2025 [November 28th, 2025]
- Gun rights groups hail Trumps pick to lead ATF: First ever truly pro-Second Amendment nominee - New York Post - November 20th, 2025 [November 20th, 2025]
- Turning Point hosts Paige Roux to talk about firearm safety and the Second Amendment - Kentucky Kernel - November 20th, 2025 [November 20th, 2025]
- The Supreme Court is more interested in Second Amendment cases than ever before - Local News 8 - November 20th, 2025 [November 20th, 2025]
- SAF FIGHTS GOVERNMENT EFFORT TO CONTINUE ENFORCING POST OFFICE CARRY BAN - Second Amendment Foundation - November 20th, 2025 [November 20th, 2025]
- SAF FILES MOTION FOR SUMMARY JUDGMENT IN MASSACHUSETTS YOUNG ADULT FIREARMS BAN - Second Amendment Foundation - November 20th, 2025 [November 20th, 2025]
- Second Amendment Legacy Foundation awards $50,000 in youth shooting sports grants - KTLO - November 20th, 2025 [November 20th, 2025]
- Second Amendment not bar to felon in possession indictment - Rhode Island Lawyers Weekly - November 20th, 2025 [November 20th, 2025]
- An Official Journal Of The NRA | This District Courts Treatment of the Second Amendment is Comically Unconstitutional - Americas 1st Freedom - November 18th, 2025 [November 18th, 2025]
- Kennedy secures veterans Second Amendment rights in deal to reopen government, renews call to stop paying Congress during shutdowns -... - November 18th, 2025 [November 18th, 2025]
- Federal Bills Introduced to Safeguard Second Amendment Rights During Government Shutdowns - NSSF | The Firearm Industry Trade Association - November 5th, 2025 [November 5th, 2025]
- Why the political arguments used by conservatives to twist the Second Amendment are a public fraud - Milwaukee Independent - November 5th, 2025 [November 5th, 2025]
- Save the Filibuster Save the Second Amendment - Gun Owners of America - November 5th, 2025 [November 5th, 2025]
- The Supreme Court Is More Interested in Second Amendment Cases Than Ever Before - The Trace - November 3rd, 2025 [November 3rd, 2025]
- SNL Weekend Update: Michael Che Says Government Still Aids Food Insecure Families Through Second Amendment After SNAP Cutoff - Deadline - November 3rd, 2025 [November 3rd, 2025]
- Supreme Court to weigh Second Amendment rights of cannabis users - inlander.com - November 3rd, 2025 [November 3rd, 2025]
- The Popular 3D-Printed Gun Globalizing the Second Amendment - Bloomberg - October 30th, 2025 [October 30th, 2025]
- The Future of the Second Amendment: A Nation Divided, Armed, and at a Crossroads - The Truth About Guns - October 30th, 2025 [October 30th, 2025]
- A warning to Florida public officials about the new open-carry law - Second Amendment Foundation - October 30th, 2025 [October 30th, 2025]
- Members Newsletter: Will SCOTUS Go Narrow in its New Second Amendment Cases? - The Reload - October 30th, 2025 [October 30th, 2025]
- I just took Everytowns online firearm training course - Second Amendment Foundation - October 28th, 2025 [October 28th, 2025]
- New Hampshire Bill Strengthening Second Amendment Rights on Public Property Advances - The Truth About Guns - October 26th, 2025 [October 26th, 2025]
- An Official Journal Of The NRA | Illegal Drugs and Second Amendment Rights - Americas 1st Freedom - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court Will Weigh Gun Restrictions for Drug Users - The New York Times - October 23rd, 2025 [October 23rd, 2025]
- The Right to Bear Technology: Americas Other Second Amendment - Andreessen Horowitz - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court adds another gun case to the docket, over drug use and the Second Amendment - MSNBC News - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will consider case on Second Amendment rights of drug users - Yahoo - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will decide if 'habitual drug users' lose their gun rights under Second Amendment - The Spokesman-Review - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will consider case on Second Amendment rights of drug users - Fox News - October 21st, 2025 [October 21st, 2025]
- Why an American raised in Rhodesia reveres the Second Amendment - Second Amendment Foundation - October 21st, 2025 [October 21st, 2025]
- In yet another move against gun ownership, California Democratic Governor Gavin Newsom recently signed Assembly Bill 1127 into law, triggering... - October 17th, 2025 [October 17th, 2025]
- Across the aisle: shootings, safety and the Second Amendment - The Muhlenberg Weekly - October 15th, 2025 [October 15th, 2025]
- Second Amendment auditors walking roads with rifle and body armor, Fla. cops say - Police1 - October 13th, 2025 [October 13th, 2025]
- The Second Amendment Holds More Weight Than Uncle Dicks Deer Stand - NSSF | The Firearm Industry Trade Association - October 11th, 2025 [October 11th, 2025]
- Supreme Court to hear Hawaii gun law case with Second Amendment implications - Baltimore Sun - October 11th, 2025 [October 11th, 2025]
- Our Next Debate: Would America Be Safer Without the Second Amendment? - The Free Press - October 9th, 2025 [October 9th, 2025]
- Fact Check Team: SCOTUS to hear Hawaii gun law case, potential impact on Second Amendment - The National Desk - October 9th, 2025 [October 9th, 2025]
- Second Amendment auditors walking Florida roads with AR-15 and body armor - Tampa Bay Times - October 9th, 2025 [October 9th, 2025]
- Fact Check Team: SCOTUS to hear Hawaii gun law case, potential impact on Second Amendment - KRCR - October 9th, 2025 [October 9th, 2025]
- Impac Mortgage : Discloses Execution of Second Amendment to Tax Benefits Preservation Rights Agreement and Execution of Amended and Restated Key... - October 9th, 2025 [October 9th, 2025]
- Supreme Court takes Second Amendment case challenging Hawaii gun law - Fox News - October 4th, 2025 [October 4th, 2025]
- Supreme Court takes case that could allow more guns in malls and restaurants - CNN - October 4th, 2025 [October 4th, 2025]
- Justices Take Up Second Amendment Case Over Hawaii's 'Affirmative Consent' Law - Law.com - October 4th, 2025 [October 4th, 2025]
- A different view on Second Amendment rights - thepress.net - October 4th, 2025 [October 4th, 2025]
- Second Amendment Roundup: Removal of Firearm Disabilities - inkl - October 2nd, 2025 [October 2nd, 2025]
- Pursuit Attractions and Hospitality, Inc. Enters into the Second Amendment to the Credit Agreement - MarketScreener - October 2nd, 2025 [October 2nd, 2025]
- Pass the CR, then fight with Truth , and the forgotten part of the second amendment. - Daily Kos - September 30th, 2025 [September 30th, 2025]
- Letters: What the Second Amendment really guarantees - NOLA.com - September 28th, 2025 [September 28th, 2025]
- The Correct Argument for the Second Amendment - The Stanford Review - September 25th, 2025 [September 25th, 2025]
- Letter to the Editor: Protect the Second Amendment - Bemidji Pioneer - September 25th, 2025 [September 25th, 2025]
- Supreme Court should revisit the Second Amendment - Wisconsin State Journal - September 21st, 2025 [September 21st, 2025]
- The Second Amendment Was Created to Put Down Slave Revolts - CounterPunch.org - September 19th, 2025 [September 19th, 2025]
- Charlie Kirks Shocking 2023 Gun Statement Goes VIRAL after Assassination | Defends Second Amendment - Oneindia - September 17th, 2025 [September 17th, 2025]
- Georgia Sheriff Calls Upon Citizens to Exercise Their Second Amendment Rights - Firearms News - September 17th, 2025 [September 17th, 2025]
- The Trump Administration's Half-Baked Plan to Disarm Transgender People Is Legally Bankrupt: Such a Gun Ban Is Not Authorized by Statute or Allowed by... - September 17th, 2025 [September 17th, 2025]
- Budget Committee Approves Ratification Bill on Second Amendment to EC-Bulgaria Financing Agreement under Recovery and Resilience Facility - - September 17th, 2025 [September 17th, 2025]
- Guns of Delusion: Who killed Charlie Kirk? America's Second Amendment obstinacy - The Times of India - September 13th, 2025 [September 13th, 2025]
- Charlie Kirks Murder Illustrates How the Second Amendment Is Swallowing the First - Slate - September 13th, 2025 [September 13th, 2025]
- Vaccines, the Second Amendment, and the Utah Supreme Court - Utah Public Radio - September 13th, 2025 [September 13th, 2025]
- Florida Court Strikes Down Open Carry Ban, Aligning Firearm Laws with Second Amendment - Hoodline - September 13th, 2025 [September 13th, 2025]
- Charlie Kirk's pro-Second Amendment stance revisited after shooting death - Daily Express US - September 13th, 2025 [September 13th, 2025]
- Florida touts big win for Second Amendment after court throws out open carry ban - Washington Examiner - September 13th, 2025 [September 13th, 2025]
- Second Amendment activists in shock as Charlie Kirk shot instead of just schoolchildren - The Beaverton - September 13th, 2025 [September 13th, 2025]
- Fact Check: Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Yahoo News UK - September 11th, 2025 [September 11th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - The Northwest Florida Daily News - September 11th, 2025 [September 11th, 2025]
- Fact Check: Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Yahoo News Canada - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Snopes - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk said "some gun deaths" were an acceptable cost for having Second Amendment gun rights - Daily Kos - September 11th, 2025 [September 11th, 2025]
- Medical Marijuana and the Second Amendment: Eleventh Circuit Revives Second Amendment Challenge to Federal Ban on Gun Ownership for Drug Users - JD... - September 11th, 2025 [September 11th, 2025]
- Charlie Kirks Pro-Gun, Second Amendment Comments Resurface After Fatal Shooting at UVU - Times Now - September 11th, 2025 [September 11th, 2025]
- Reader says protect Second Amendment rights, but reduce access to some firearms - San Antonio Express-News - September 11th, 2025 [September 11th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - Lakeland Ledger - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk, shot dead in Utah, once said gun deaths are 'worth it' to save Second Amendment - Firstpost - September 11th, 2025 [September 11th, 2025]
- Florida will have a Second Amendment sales tax holiday. Here's what to know - Pensacola News Journal - September 9th, 2025 [September 9th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - yahoo.com - September 9th, 2025 [September 9th, 2025]
- Florida Second Amendment Sales Tax Holiday begins, runs through end of the year - Floridas Voice - September 9th, 2025 [September 9th, 2025]
- Marylands Handgun Roster Board: a rubber stamp or assault on Second Amendment? - Baltimore Sun - September 6th, 2025 [September 6th, 2025]
- Tennessee joins other states on Second Amendment SCOTUS brief - WKRN News 2 - September 6th, 2025 [September 6th, 2025]