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Constitutional Law Keyed to Shanor
New York State Rifle & Pistol Association v. Bruen
Citation:
597 U.S. 1 (2022)Facts
Petitioners Brandon Koch and Robert Nash are law-abiding adult citizens of Rensselaer County, New York. Both applied for unrestricted licenses to carry handguns for self-defense in public but were issued only restricted licenses permitting them to carry for hunting and target shooting. When they requested the removal of these restrictions, citing general self-defense concerns, the licensing officer (a New York Supreme Court justice) denied their requests, stating they had not demonstrated “proper cause” as required by New York law. Under New York’s regime, applicants must show a special need for self-protection distinguishable from the general community to obtain an unrestricted concealed carry license. This “proper cause” standard has been interpreted by New York courts to require evidence of “particular threats, attacks or other extraordinary danger to personal safety.” The petitioners, along with the New York State Rifle & Pistol Association, sued in federal court, claiming that New York’s proper-cause requirement violated their Second and Fourteenth Amendment rights.
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