By Tanya Metaksa
What’s New —SCOTUS: Calce, et al., Petitioners v. City of New York; Case No. 26-46: Jul 07 2026 Petition for a writ of certiorari filed; Next Orders list on Aug. 17; Reaction to Glock‑targeted “convertible pistol” bans—An emerging Second Amendment problem: Four states have enacted Glock‑targeted “convertible pistol” bans to date: California and Maryland already have litigation filed against the new laws; while litigation is being considered in Connecticut and New York; State Courts: Pennsylvania: Supreme Court: Punksutawney Hunting Club,Inc. and Pitch Pine Hunting Club, Inc. v. Pennsylvania Game Commission; A 7-0 decision in favor of the Hunting Clubs; Virginia: Lancaster County Court: Crump v. Katz,: Preliminary injunction issued.
SCOTUS
Although SCOTUS is on its summer recess, summer order lists are scheduled to be issued on Monday, Aug. 17; and Friday, Sept. 4. Summer order lists usually consist of actions taken by the Court on motions in pending cases, petitions for rehearing, and other miscellaneous matters. Emergency orders, such as in applications for stays, will continue to be released as required.
Calce, et al., Petitioners v. City of New York; Case No. 26-46: Jul 07 2026 Petition for a writ of certiorari filed.
Background: Calce v. City of New York was filed in the Southern District of New York as No. 1:21-cv-08208. The district court, in a March 24, 2025 opinion and order by Judge Edgardo Ramos, denied plaintiffs’ motion for summary judgment and granted the City’s cross-motion for summary judgment, closing the case in the City’s favor.
Second Circuit: The appeal was docketed in the Second Circuit as No. 25-861. The Second Circuit issued a summary order on April 13 and affirmed the district court’s judgment, leaving the City’s stun-gun and taser bans in place.
Reaction to Glock‑targeted “convertible pistol” bans
An emerging Second Amendment problem
Several states have enacted Glock‑targeted “convertible pistol” bans to date. So far they are California, Maryland, and Connecticut, with New York having enacted a closely related “convertible pistol” regime in its 2026 budget bill that effectively functions as a forward‑looking Glock‑style sales ban. All of these laws target semiautomatic pistols (primarily Glock and Glock‑style) that can be converted into “DIY machine guns” by adding a Glock‑switch–type conversion device, and each has already triggered or attracted significant Second Amendment litigation or announced challenges.
Below is a state‑by‑state overview to help you follow the litigation and the Bruen‑style judicial thinking of the plaintiffs.
California: California is the earliest and most developed example, and is currently drawing both private and federal challenges.
- Statute and structure
- Assembly Bill 1127, signed by Gov. Newson on Oct. 10, 2025, prohibits licensed dealers from selling or transferring any “semiautomatic machinegun‑convertible pistol,” defined by design features (not by brand) that allow easy conversion with a “Glock switch.”
- The law targets pistols with a cruciform trigger bar or similar mechanism, which includes “virtually all Glock and Glock‑style pistols,” and removed over 30 Glock models from the state’s Handguns Certified for Sale roster as of early 2026.
- Existing owners may retain their pistols, and private‑party transfers and law enforcement/military acquisitions remain largely unaffected; the primary effect is to choke off new retail sales through licensed dealers.
- Filed challenge
- NRA/FPC/SAF suit – Jaymes v. Bonta: Case No: 3:25‑cv‑02711; Judge John A. Houston; U.S. District Court for the Southern District of California. NRA, Firearms Policy Coalition, Second Amendment Foundation, and individual plaintiffs filed a federal suit arguing AB1127 is a categorical handgun ban in violation of Heller and Bruen, because it bars sale of one of the “most popular handguns in America.”
- United States v. California (DOJ suit): The Trump DOJ filed its own complaint in federal district court challenging AB 1127 and aspects of California’s handgun roster, explicitly characterizing AB 1127 as a “Glock Ban” that unconstitutionally bars the sale of virtually all Glock‑style pistols.
- Both complaints lean into “common use” and attack the state’s attempt to define these pistols as “machinegun‑convertible” when the conversion devices themselves are already banned under federal law.
Maryland: Maryland’s law is structurally similar to California’s but framed as a “machine gun convertible pistol” ban with a delayed effective date and multiple coordinated challenges.
- Statute and structure
- Senate Bill 334, signed by Gov. Wes Moore on May 26, bans the manufacture, sale, purchase, receipt, or transfer of “machine gun convertible pistols,” defined as pistols built around a cruciform trigger bar that can be easily converted with illegal switches.
- The law, which takes effect Jan. 1, 2027, (next year) is expressly aimed at handguns “easily and quickly converted into fully automatic ‘DIY machine guns,’” with legislative and advocacy materials acknowledging that this effectively covers most Glock and Glock‑style handguns.
- Advocacy groups identify Maryland as the second state after California to enact a Glock‑targeted “convertible pistol” sales ban.
- Filed challenges
- NRA/FPC/SAF coalition suit (filed May 26, 2026): NRA, Firearms Policy Coalition, and Second Amendment Foundation filed suit in federal court the day SB334 was signed, arguing that it bans “many of the most popular handguns in America” in violation of Heller’s common‑use protection.
Bathras et al. v. Moore; Case No. 1:26-cv-02074-JRR (U.S. District Court for the District of Maryland), Judge Julie Rebecca Rubin. Brought by SAF, NRA and FPC as an unconstitutional handgun ban and recently moved for a preliminary injunction; briefing emphasizes that the state is banning otherwise lawful pistols instead of the already‑illegal conversion devices.
- These suits are in the Fourth Circuit pipeline, with commentators noting that both the district court and the Fourth Circuit are historically unfriendly venues for Second Amendment plaintiffs, increasing the odds of eventual cert‑level positioning.
Connecticut: Connecticut followed California and Maryland with its own Glock‑style sales prohibition, focused on “convertible pistols” and likewise motivated by Glock‑switch concerns.
- Statute and structure
- House Bill 5043, framed as a ban on “pistols capable of being converted into fully automatic weapons,” passed the Connecticut House in April 2026 and ultimately reached the governor’s desk.
- Gov. Ned Lamont signed a bill in June 2026 “banning the sale of certain Glock‑style pistols,” with coverage making clear the primary target is handguns that can be converted via Glock‑switch‑type devices.
- In legislative and media descriptions, the bill is repeatedly compared to California and Maryland’s efforts to stop new retail sales of “convertible pistols,” while not criminalizing current owners of those handguns.
- The governor’s office situates this within a broader package of measures (including a 2025 public‑nuisance/industry‑accountability statute), treating the design‑based Glock restriction as an extension of manufacturer “reasonable controls” requirements.
- Litigation posture
- As of the latest reporting, major gun‑rights groups have signaled intent to challenge the Connecticut ban on Glock‑style pistols, but detailed coverage of a filed federal complaint is not yet as developed or prominently reported as in California or Maryland.
- Given the state’s 2025 gun‑industry accountability law that already invites civil suits against manufacturers, you are likely to see parallel Second Amendment and PLCAA‑adjacent challenges once a clean plaintiff with standing emerges (e.g., an in‑state dealer or prospective purchaser of a Glock model barred solely by the new definition).
New York: New York has arrived at a similar endpoint through its broader “convertible pistol” and pistol‑converter regime embedded in the FY 2027 budget and follow‑on implementing provisions.
- Statutes and structure
- A legislative package built around S.399/A.199 and then folded into the FY 2027 budget amends the Penal Law to regulate “pistol converters” and “convertible pistols,” targeting semiautomatic pistols that can be turned into “DIY machine guns” via Glock switches.
- The enacted regime prohibits the future sale of semi‑automatic pistols that can be easily converted into fully automatic weapons with a Glock switch, while leaving current owners unaffected—functionally emulating California’s and Maryland’s forward‑looking Glock‑style sales bans.
- An implementation bulletin for police chiefs explains that, effective Aug. 25, a convertible pistol equipped with a pistol converter is treated as a machine gun under New York law; the statute also narrows permitted commercial channels for convertible pistols themselves, with categorical exemptions for police and peace officers.
- Litigation posture
- Commentators note that industry groups and Second Amendment advocates have “already signaled their intent to challenge the law,” anticipating Bruen‑focused litigation given New York’s recent track record in post‑Bruen gun cases.
- At least as of late May–June 2026 commentary, those challenges were expected but not yet crystallized into a particular captioned federal case in widespread reporting, unlike Jaymes v. Bonta or Bathras v. Moore.
- New York already has an enhanced gun‑industry accountability law that explicitly requires manufacturers to take steps to prevent their handguns from being easily converted with Glock switches, providing a second front of potential litigation over both statutory design‑features mandates and civil liability exposure. It may be likely that there will be a National Shooting Sports Foundation (NSSF) lawsuit.
High‑level pattern across states
Across these states, several common themes are emerging, which include at this time the following:
- Design‑based bans, not brand‑name bans. None of the statutes literally says “Glock,” but all use functional definitions—“machinegun‑convertible pistols,” pistols with cruciform trigger bars, or “convertible pistols” readily modified with a Glock switch—that have the practical effect of sweeping in most Glock and Glock‑pattern pistols.
- Forward‑looking sales restrictions. All of the measures focus on stopping new commercial sales and transfers through licensed dealers, typically leaving existing owners untouched and often exempting law enforcement, which helps the states argue that they are not confiscation schemes but “safety standards” for future commerce.
- Reliance on already‑illegal conversion devices. The state narrative is that Glock switches and similar converters are driving machine‑gun‑like violence, and that design‑based restrictions on pistols are necessary to “hold manufacturers accountable” beyond prohibiting switches themselves; plaintiffs counter that switches are already illegal under the NFA and that the state is banning ordinary semiautomatic handguns instead of the criminal conduct.
- Second Amendment theory of the challenges. Gun‑rights plaintiffs and the DOJ characterize these laws as bans on “the most popular handgun in America” and therefore unconstitutional under Heller’s common‑use rule, with Bruen supplying the test that leaves little room for modern, technology‑specific handgun bans absent a robust historical analog.
- Likely expansion to additional states. Advocacy materials and commentators explicitly predict similar “convertible pistol” or Glock‑style bans in states such as Illinois, New Jersey, Colorado, New Mexico, and Virginia, some of which already have public‑nuisance suits pending against Glock.
State Courts
Pennsylvania: Supreme Court
Punksutawney Hunting Club,Inc. and Pitch Pine Hunting Club, Inc. v. Pennsylvania Game Commission; No. 23 WAP 2023, In The Supreme Court of Pennsylvania-Western Division; decided July 21.
In an 83-page, 7-0 decision the Court reexamined ”their prior decision in Commissioner v. Russo in the context of a constitutional challenge to portions of the Game and Wildlife Code (Code), which expressly empower officials of the Pennsylvania Game Commission (Commission) to go upon or enter private property, posted or otherwise.” The Court then concluded “that slavish adherence to our decision in Russo must give way to the greater privacy and property protections afforded under Article I, Section 8 of our state charter. As our jurisprudence in this area has evolved, the Court’s reasoning and result in Russo have not aged well. In short, we hold that: (a) Russo was wrongly decided; (b) Article I, Section 8 of the Pennsylvania Constitution affords greater protection to land beyond the curtilage of a home or building; and (c) most of the challenged Entry Statutes are, consequently, unconstitutional.”
Virginia: Lancaster County Court
Crump v. Katz,: We covered this case in the Judicial Report of July 17. The available accounts confirm that Lancaster County Circuit Judge John Martin issued a preliminary injunction sometime during the week of June 20, in Crump v. Katz, blocking Virginia State Police from enforcing the new assault-weapons and magazine ban before July 1. TheReload.com published an article regarding Judge Martin’s preliminary injunction that reviews what has happened after temporary injunctions have been invoked on laws banning guns. As of now, most Virginia gun stores are selling AR-15s and magazines with a capacity greater than 10 rounds.
