By Tanya Metaksa
What’s New – SCOTUS- Gardner v. Maryland Massachusetts: First Circuit: Granata v. Campbell: Case No. 22-1478 and 25-1918: Federal Second Amendment constitutional challenge to Massachusetts’ Approved Firearms Roster and Attorney General’s Handgun Sales Regulations; Georgia State Court: Deacon Morris & Firearms Policy Coalition, Inc. v. The Mayor and Alderman of the City of Savannah: No. SPCV25-00883-KA (Superior Court of Chatham County, State of Georgia): Complaint for declaratory, injunctive, and damages relief, seeking to have a Savannah ordinance regulating the possession of firearms in vehicles declared void and unenforceable.
SCOTUS
Conference was scheduled for April 17—Eva Gardiner v. Maryland (right to travel with a handgun) and George Peterson v. United States (NFA suppressor prosecution) were denied certiorari; Granata v. Campbell: Case No. 22-1478 and 25-1918: Federal Second Amendment constitutional challenge to Massachusetts’ Approved Firearms Roster and Attorney General’s Handgun Sales Regulations; Deacon Morris & Firearms Policy Coalition, Inc. v. The Mayor and Alderman of the City of Savannah: No. SPCV25-00883-KA (Superior Court of Chatham County, State of Georgia): Complaint for declaratory, injunctive, and damages relief, seeking to have a Savannah ordinance regulating the possession of firearms in vehicles declared void and unenforceable;
All cases that are granted certiorari at this date and later will be heard during the Court’s 2026-2027 term that begins in October 2026, with decisions in June 2027. In a video, Mark W. Smith, Second Amendment attorney (@FourBoxesDiner on X.com and the Four Boxes Diner on YouTube.com), who reviews current cases, suggested that the justices may be “clearing the deck” of non‑AR‑15 and non‑magazine cases now, anticipating grants in more broadly impactful 2A matters involving rifle bans, magazine limits, and age‑based restrictions. Let’s hope he is reading the tea leaves correctly.
U.S. Court of Appeals
Massachusetts: First Circuit
Granata v. Campbell: Case No. 22-1478 and 25-1918: Federal Second Amendment constitutional challenge to Massachusetts’ Approved Firearms Roster and Attorney General’s Handgun Sales Regulations. It addresses whether the state may bar the commercial sale of handguns that are in common use for lawful purposes while still allowing possession and out‑of‑state acquisition. On April 16, FPC filed a reply brief.
Case overview
- Plaintiffs (individual gun buyers, a dealer, and Firearms Policy Coalition) challenge Massachusetts’s roster and AG regulations as an unconstitutional ban on the commercial sale of commonly used handguns under the Second and Fourteenth Amendments.
- Defendants are the Massachusetts Attorney General (currently Andrea Campbell) and the Secretary of Public Safety, responsible for enforcing the roster and handgun regulations.
- The case started as Granata v. Healey, survived a First Circuit remand after Bruen, and is now called Granata v. Campbell in the First Circuit on appeal from summary judgment for the state.
Pre-Bruen proceedings
- The First Circuit previously heard an appeal from the original dismissal and, on April 7, 2023, summarily vacated and remanded for reconsideration under Bruen, explicitly taking no position on the district court’s pre-Bruen decision.
Post-Bruen
- On Aug. 29, 2025, the District Court issued a summary judgment in favor of the state. Plaintiffs filed an appeal, now docketed as No. 25‑1918, Granata et al. v. Campbell et al., in the U.S. Court of Appeals for the First Circuit.
- At the appellate level, the First Circuit is reviewing the case under the Bruen framework to determine whether Massachusetts’ roster and handgun sales regulations are consistent with the nation’s historical tradition of firearm regulation. It is also examining whether the district court erred by considering limits on commercial sales of commonly used handguns as outside the scope of the Second Amendment, especially since alternative firearms or out-of-state purchases remain available. The Firearms Policy Coalition is pursuing the appeal, and in January 2026, the U.S. Department of Justice’s Civil Rights Division filed an amicus brief supporting the plaintiffs, arguing that Massachusetts’ scheme unconstitutionally bans sales of handguns commonly possessed for lawful purposes and criticizing the district court’s reasoning as incompatible with Bruen.
- Currently, the case is pending in the First Circuit; briefing includes the plaintiffs’ opening brief, Massachusetts’ response, multiple amici (including gun-control groups for the state and DOJ for the plaintiffs), and FPC’s reply filed on April 16.
State Court
Georgia State Court
Deacon Morris & Firearms Policy Coalition, Inc. v. The Mayor and Alderman of the City of Savannah: No. SPCV25-00883-KA (Superior Court of Chatham County, Georgia): Complaint for declaratory, injunctive, and damages relief, seeking to have a Savannah ordinance regulating the possession of firearms in vehicles declared void and unenforceable on the grounds that the ordinance is preempted by state law, the Georgia Constitution, and is beyond the city’s authority, and to recover damages incurred as a result of the Defendant’s enforcement of this law.
Case Overview
- Plaintiffs are Deacon Morris, an individual gun owner and member of the Firearms Policy Coalition (FPC), and Firearms Policy Coalition, Inc., a nonprofit organization dedicated to protecting gun rights.
- The defendants are the Mayor and Aldermen of the City of Savannah, sued in their official capacities. On April 11, 2024, the Savannah City Council adopted two ordinances: § 9-1027, titled “Report of Theft or Loss of a Firearm, Rifle, or Shotgun,” and § 9-1028, titled “Secured Storage of Firearms, Rifles, and Shotguns in Parked Vehicles.”
Factual background and injury
- On Aug. 9, 2024, Savannah police cited Morris for an alleged violation of § 9‑1028(c), which mandates that all doors and hatches be locked when a vehicle containing a firearm is unoccupied.
- On Oct. 28, 2024, during the case call in Chatham County Recorder’s Court, the City announced orally that it would enter a nolle prosequi and give Morris only a warning.
- Although the City did not pursue the charge to conviction, Morris and FPC claim they incurred attorneys’ fees and costs for responding to the citation and the “illegal ordinance” and its enforcement.
FPC covered the costs of Morris’s legal representation in defending against the citation.
Claims and legal theory
- The complaint states that the ordinances are illegal under Georgia’s firearm preemption law, O.C.G.A. § 16‑11‑173, and the restrictions on local laws in the Georgia Constitution, and that the City “has no authority to pass the ordinance.”
- Plaintiffs contend that the ordinances directly regulate how firearms are stored, transported, and secured in unattended vehicles, thereby governing the “possession, transport, or carrying” of firearms in violation of O.C.G.A. § 16‑11‑173(b)(1).
- The suit seeks a declaration that the ordinances are preempted by state law, violate a clear constitutional mandate, and are ultra vires and void, and requests recovery of damages and other relief for costs incurred in enforcement against Morris.
State preemption context and Attorney General involvement
- Before this lawsuit, the Georgia Attorney General’s Office sent a May 2024 letter to Savannah officials stating that these ordinances “directly conflict with and are preempted by” Georgia law, which explicitly forbids local regulation of firearm possession, transport, or carrying, and urged the City to rescind them while warning of potential civil liability. Despite the Attorney General’s letter, Savannah refused to repeal the ordinances, and the Morris litigation followed.
- On July 28, 2025, the Georgia Attorney General submitted an amicus brief in Morris v. Savannah, asserting that §§ 9‑1027 and 9‑1028 infringe on the General Assembly’s authority over firearm regulation and that O.C.G.A. § 16‑11‑173 requires the court to declare the ordinances ultra vires and invalid.
- Separately, in November 2025, a judge from Chatham County Recorder’s Court ruled in a criminal case against another defendant that Savannah’s gun-storage ordinance violates Georgia’s preemption statute and “burdens conduct covered by the plain text of the Second Amendment,” making it invalid and unenforceable for that defendant, although the decision officially applied only to that case.
Procedural posture and latest April 2026 filing: On April 14, plaintiffs (Morris and FPC) filed a motion for summary judgment in the Superior Court case, seeking to “enjoin [the] illegal Savannah, Ga. gun control law” and obtain declaratory and injunctive relief against enforcement.
