By Tanya Metaksa
What’s New – No Second Amendment cases were addressed after the March 20 SCOTUS conference. California: Ninth Circuit: Junior Sports Magazines Inc., et al. v. Bonta: Case No. 24‑4050: A rousing victory; New York: Second District: Antonyuk v. Hochul: Case No, 1:22-cv-00986:On March 16, a stipulation of partial settlement removed the controversial provision of its strict requirements for concealed carry permit applicants; Pennsylvania Supreme Court: Commonwealth v. Williams: No. 182 MDA 2024: The Second Amendment Foundation, the NRA, and Firearms Owners Against Crime filed an amicus brief in this case that urged the Court to strike those restrictions down under Bruen’s text‑and‑history test.
SCOTUS
Next Conference March 27, 2026
As of March 25, a listing of all the Second Amendment cases awaiting certiorari decisions, with the exception of § 922(g)(1) cases.
Gator’s Custom Guns v. Washington, Case No. 25-153, Case issue: Whether magazines over 10 rounds are “Arms” under the Second Amendment.
Duncan v. Bonta, Case No. 25-198, Case issue: Whether magazines over 10 rounds are “Arms” under the Second Amendment.
Viramontes v. Cook County, Case No. 25-238, Case issue: Whether the Second and Fourteenth Amendments guarantee the right to possess semiautomatic rifles in common lawful use, including the AR-15.
Association for Gun Rights v. Lamont, Case No. 25-421, Whether a ban on AR‑15‑style rifles and magazines over 10 rounds violates the Second Amendment.
Grant v. Higgins, Case No. 25-566, Whether the Second and Fourteenth Amendments guarantee the right to possess semiautomatic rifles in common lawful use, including the AR-15.
Schoenthal v. Raoul, Case No. 25-541, Whether Illinois’ flat ban on carrying firearms on public transportation violates the Second and Fourteenth Amendments.
McCoy v. ATF, Case No. 25-24,. Federal ban on 18-200tear-olds buying handguns from FFLs under the Second Amendment.
Paris v. Second Amendment Foundation, Case No. 24-1329, Whether minimum age-21 firearms laws violate 18-20-year-olds’ asserted Second Amendment rights.
United States v. George Peterson, Case No. 24-30043. Whether the district court erred in holding that silencers are not “bearable arms.”
Gardner v. State of Maryland: Case No. 25-5961. Whether prosecuting a law‑abiding, out‑of‑state resident for carrying a handgun for self‑defense while traveling, when she complies with her home state’s law and possesses a valid Virginia permit, violates the Second and Fourteenth Amendments.
Court of Appeals
California: Ninth Circuit:
Junior Sports Magazines Inc., et al. v. Bonta: Case No. 24‑4050.
The California Rifle and Pistol Association recently stated:
- CRPA is thrilled to celebrate a rousing victory in the case of Junior Shooting Sports Magazines, Inc. v. Bonta, our case challenging the ban on any marketing of firearms or firearms-related products or events that could be construed as “targeting minors.”
- “This full and complete victory is a result of the tenacity of the CRPA and our attorneys, who pushed this case not once but twice through the Ninth Circuit,” stated CRPA President & General Counsel Chuck Michel. “The state recklessly shoved aside both the First and Second Amendments, but AB 2571 has been rightfully struck down.”
Background:
Junior Sports Magazines Inc., et al. v. Bonta in the Central District of California, No. 2:22‑cv‑04663‑CAS‑JC.
The litigation began on July 8, 2022, when plaintiffs filed Junior Sports Magazines Inc., et al. v. Bonta, along with a motion for preliminary injunction challenging newly enacted § 22949.80. The district court denied preliminary relief in November 2022, and plaintiffs noticed an interlocutory appeal on November 21, 2022, docketed in the Ninth Circuit as Junior Sports Magazines Inc. v. Bonta, No. 22‑56090; after argument in June 2023, the panel issued a published opinion on September 13, 2023 (80 F.4th 1109), reversing and remanding with instructions to enjoin the statute. On remand, the district court enjoined only subsection (a), leaving subsection (b) in place, prompting plaintiffs’ second interlocutory appeal, noticed June 28, 2024, and docketed as Junior Sports Magazines Inc., et al. v. Bonta, No. 24‑4050, again under 28 U.S.C. § 1292(a)(1). Following briefing on an accelerated injunction calendar and argument in June 2025, the Ninth Circuit issued a memorandum disposition on July 7, 2025, clarifying that its prior reasoning applied to “the entirety” of § 22949.80 and directing that all of the statute be enjoined; the mandate issued and was spread on the district‑court record in September 2025, and the court thereafter entered final judgment and a permanent injunction in plaintiffs’ favor.
District Court
New York: Second District
Antonyuk v. Hochul: Case No. 1:22-cv-00986:
On March 16, a stipulation of partial settlement removed the controversial requirement for concealed carry permit applicants. Under a new settlement agreement, the state will no longer enforce its social media disclosure requirement.
“The State Defendants consent to the entry of an injunction against their enforcement of N.Y. Penal Law § 400.00(l)(o)(iv), which requires applicants for a concealed carry license to provide ‘a list of former and current social media accounts of the applicant from the past three years to confirm the information regarding the applicants character and conduct as required in’ N.Y. Penal Law § 400.00(l)(o)(ii), against any Plaintiff. The Superintendent shall ensure that the PPB-3 license application form does not include language requiring social media information.”
Yet, this is only part of the lawsuit against NY’s CCIA that was passed after the U.S. Supreme Court decided the case of the New York State Rifle and Pistol Association v. Bruen. The challenges to the remaining contentious provisions will continue before Judge Glenn Suddaby in the District Court.
State Court
Pennsylvania: Pennsylvania Supreme Court
Commonwealth v. Williams: No. 182 MDA 2024: Amicus Brief
Commonwealth v. Williams is an appeal to the Pennsylvania Supreme Court from a conviction under 18 Pa.C.S. § 6106, stemming from a routine traffic stop where police found 19-year-old Kareem Mohammed Williams Jr. with a handgun in a fanny pack while a passenger in a vehicle. Because Pennsylvania law categorically denies Licenses to Carry Firearms to adults under 21, Williams—though an otherwise law-abiding adult—could not lawfully obtain the license required to carry a concealed firearm or transport a firearm in a vehicle, and he was convicted of a third-degree felony for carrying a firearm without a license. He moved to dismiss the charge, arguing that as an 18- to 20-year-old adult, he is among “the people” protected by the Second Amendment and Article I, § 21, and that Pennsylvania’s under-21 licensing ban, along with § 6106’s vehicle-carry prohibition, functions as a categorical ban on everyday young adult carry that cannot be aligned with the Nation’s historical firearm regulation tradition under Bruen. The trial court denied the motion, a Superior Court panel upheld the decision—finding that the restrictions are “relevantly similar” to historical public-carry regulations and that Article I, § 21 offers no greater protection than the Second Amendment—and the Pennsylvania Supreme Court agreed to review it.
The Second Amendment Foundation, the NRA, and Firearms Owners Against Crime filed an amicus brief in this case that urged the Court to strike those restrictions down under Bruen’s text‑and‑history test. The questions presented are whether law‑abiding 18‑ to 20‑year‑old adults such as Williams fall within “the people” whose right to keep and bear arms is protected by the Second Amendment and Article I, § 21; and, if so, whether Pennsylvania may nonetheless enforce a statutory scheme that categorically denies them carry licenses and thereby criminalizes their otherwise ordinary carriage and vehicle transport of handguns, consistent with this Nation’s historical tradition of firearm regulation as required by Bruen.
