Legal Definitions - New York State Rifle & Pistol Association (NYSRPA) v. Bruen (2022)

New York State Rifle & Pistol Association (NYSRPA) v. Bruen is a Supreme Court case that deals with the interpretation of the Second Amendment. The case reaffirms the precedent set in District of Columbia v. Heller and prohibits the use of “means-end” tests when evaluating the constitutionality of firearm restrictions.

The case involved a New York gun control law that required individuals interested in obtaining a handgun to first obtain a license. These licenses were for specific uses only, and if someone wanted a license to carry a handgun in public, they had to show “proper cause” as to why they had a heightened need for self-protection over the general population. Permits were issued on a “may-issue” basis, meaning government officials had the final say as to whether “proper cause” was shown.

The Supreme Court held that the New York law was unconstitutional because it issued licenses on a “may-issue” basis rather than a “shall-issue” basis. A “may-issue” licensing system allows a governmental body to deny a citizen a firearm at the government’s discretion, which contradicts the central holding of District of Columbia v. Heller. The Court also rejected the “two-step” analysis many jurisdictions used to determine the constitutionality of gun restrictions.

Justice Kavanaugh, joined by Justice Roberts, emphasized that Bruen is not intended to invalidate “shall-issue” licensing structures or other restrictions on firearm ownership, including fingerprinting, background checks, mental health evaluations, mandatory training requirements, and potential other requirements.

Justice Barrett wrote a separate concurrence which joined the opinion in full, but cited two unresolved issues that the court will likely have to tackle in the future.

Justice Breyer, joined by Justice Kagan and Justice Sotomayor, dissented on grounds that using a “means-end” test is proper.

Example: A person in New York wants to obtain a license to carry a handgun in public for self-protection. Under the New York law, they would have to show “proper cause” as to why they have a heightened need for self-protection over the general population. If government officials deemed their general desires for self-protection insufficient, they would be denied a license. This law was challenged in court by two parties who were denied a public carry license after government officials deemed their general desires for self-protection were an insufficient showing of “proper cause” to establish a heightened need.

Explanation: The example illustrates how the New York gun control law required individuals to show “proper cause” to obtain a license to carry a handgun in public. The law was challenged in court by individuals who were denied a license, and the Supreme Court ultimately held that the law was unconstitutional because it issued licenses on a “may-issue” basis rather than a “shall-issue” basis.