FPC LAW RESEARCH & AMICUS DOCKET
See here for a comprehensive overview of active FPC Law lawsuits organized by jurisdiction/state.
Below are links to and information about some important amicus briefs to defend and advance YOUR RIGHTS.
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FPC 2A Legal Tracker: Track cases and important filings.
RESEARCH
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The Right to Train: A Pillar of the Second Amendment
- Joseph G.S. Greenlee
- William & Mary Bill of Rights Journal, Vol. 31, 2022 (Forthcoming)
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The American Tradition of Self-Made Arms
- Joseph G.S. Greenlee
- Volume 54 of the St. Mary’s Law Journal in 2022
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Red Flag Laws Raise Red Flags Of Their Own
- Joseph G.S. Greenlee and Matthew Larosiere
- 45 Law & Psychol. Rev. 155 (2020-2021)
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The Historical Justification For Prohibiting Dangerous Persons From Possessing Arms
- Joseph G.S. Greenlee
- 20 Wyo. L. Rev. 249 (2020)
Click here for Joseph Greenlee's SSRN author page listing of more research/articles
SYMPOSIUMS & EVENTS
- Restoring the Founders’ right to bear arms
- Joseph G. S. Greenlee, SCOTUSblog (Jun. 29, 2022, 1:42 PM)
AMICUS BRIEFS
FEDERAL COURTS
U.S. Supreme Court
July 1, 2022 - United States Supreme Court
- Torcivia v. Suffolk County
- Lawsuit challenging the government’s ability to enter private homes and seize firearms from an individual suspected of no crime, and subject to no penal control or supervision
- Motion For Leave to File Brief and Brief of Amici Curiae Firearms Policy Coalition and FPC Action Foundation in Support of Petitioner
- Press Release
March 25, 2022 - United States Supreme Court
- Morin v. Lyver
- Lawsuit challenging Massachusetts’s lifetime ban on firearm purchases as applied to a person convicted of a non-violent misdemeanor
- Cert Petition
- Brief of Amici Curiae Firearms Policy Coalition and FPC Action Foundation in Support of Petitioner
- Press Release
September 3, 2021 - United States Supreme Court
- Aposhian v. Garland: Lawsuit challenging the federal bump stock ban.
- Brief of Damien Guedes, Shane Roden, Firearms Policy Foundation, Madison Society Foundation, Inc., and Florida Carry, Inc. as Amici Curiae Supporting Petitioner
July 20, 2021 - United States Supreme Court
- NYSRPA v. Bruen: Case from New York involving the right to bear arms in public.
- Brief of the Firearms Policy Coalition and Professor Joyce Lee Malcolm, Brief of California Gun Rights Foundation, Brief of Amici Curiae William English, Ph.D. and The Center For Human Liberty, Amicus brief of FPC American Victory Fund, et al., Amicus brief of Madison Society Foundation, Inc.
- FPC Press Release, CHL Press Release, FPC-AVF Press Release, MSF Press Release
July 13, 2021 - United States Supreme Court
- NYSRPA v. Bruen: Case from New York involving the right to bear arms in public.
- Brief of amici curiae Professors of Second Amendment Law, Weld County, Colorado, Weld County Sheriff Steve Reams, Independence Institute, and Firearms Policy Foundation
- Press Release
June 25, 2021 - United States Supreme Court
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Young v. Hawaii: Challenging Hawaii’s laws and policies that prevent law-abiding people from exercising their right to carry firearms in public for self-defense.
- Brief of Amici Curiae Firearms Policy Coalition and Firearms Policy Foundation In Support of Petitioner
- Press Release
May 17, 2021 - United States Supreme Court
- Caniglia v. Strom, et al.: Case about whether a “community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home.
- Amicus brief of FPC, FPF, and Independence Institute
- Opinion
- Press Release
April 9, 2021 - United States Supreme Court
- Mahanoy Area School District v. B.L.: Imploring the Court to protect off-campus student speech
- Amicus Curiae Brief of The Liberty Justice Center and Firearms Policy Coalition in Support of Respondents
- Press Release
March 24, 2021 - United States Supreme Court
- Caniglia v. Strom, et al.: Case about whether a “community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home.
- Amicus brief of FPC, FPF, and Independence Institute
- Oral Argument Audio
March 2, 2021 - United States Supreme Court
- Americans for Prosperity v. Becerra and Thomas More Law Center v. Becerra: Two cases were consolidated by the Court to answer whether a California law requiring charities to disclose IRS Form 990 Schedule B donor information violates the First Amendment.
- Amicus brief
- Press Release
February 3, 2021 - United States Supreme Court
- Flick v. Wilkinson: Case challenging the federal lifetime firearms prohibition for felons.
- Amicus brief of FPC and FPF
- Press Release
January 28, 2021 - United States Supreme Court
- Maryland Shall Issue, Inc., et al., v. Hogan: Case challenging the Maryland government’s confiscatory ban on bump-stock devices.
- Amicus brief of FPC
- Press Release
January 21, 2021 - United States Supreme Court
- NYSRPA v. Bruen: Case from New York involving the right to bear arms in public.
- Amicus brief of FPC and FPF
- Press Release
January 15, 2021 - United States Supreme Court
- Caniglia v. Strom, et al.: Case about whether a “community caretaking” exception to the Fourth Amendment’s warrant requirement extends to the home.
- Amicus brief of FPC, FPF, and Independence Institute
- Press Release
October 1, 2020 - United States Supreme Court
- Torres v. United States - Brief filed in support of Petitioner's Writ of Certiorari to restore nonviolent felon's 2nd Amendment rights
- FPC: Supreme Court Should Decide Non-Violent Felons Have Second Amendment Rights, Lifetime Ban Should Be Struck Down
- Challenges the federal prohibition on firearm ownership by felons, as it applies to nonviolent felons. Specifically, Mr. Torres was convicted of a felony and is subject to a lifetime firearms prohibition based on a DUI offense. After the Ninth Circuit upheld this firearms ban earlier this year, Mr. Torres petitioned the Supreme Court to hear his case.
July 24, 2020 - United States Supreme Court
- Brief in support of Petitioner Zoie H.
- Case of Zoie H. v. Nebraska (Supreme Court no. 19-1418)
- FPC brief shows why Nebraska’s treatment of the Second Amendment through its law depriving gun rights without a jury trial contradicts the Constitution's text, history, and tradition
- FPC was joined by FPF and fellow amici California Gun Rights Foundation, Madison Society Foundation, Second Amendment Foundation, Independence Institute, and Second Amendment law professors and scholars Nicholas Johnson (Fordham), Donald Kilmer (Lincoln), George Mocsary (Wyoming), Joseph Olson (Mitchell Hamline), Glenn Reynolds (Tennessee), and Gregory Wallace (Campbell).
- Related news release here
March 6, 2020 - United States Supreme Court
- Merits stage amicus brief in support of the Presidential Electors on behalf of Independence Institute in the matter of Chiafalo, et al. v. Washington & Colorado Dept. of State v. Baca, et al.
- FPC Director of Research, Joseph Greenlee, co-authored with Independence Institute Research Director, David Kopel
December 19, 2019 - United States Supreme Court
- Reply brief in support of petition for certiorari filed in Guedes, et al. v. Attorney General William Barr, et al.
- Federal challenge to the government's unlawful ban on "bump-stock" devices
- Related news release here
October 30, 2019 - United States Supreme Court
- FPC Brief in Support of Petitioners (PDF)
- FPC was joined on the brief by Firearms Policy Foundation, California Gun Rights Foundation, Second Amendment Foundation, and Madison Society Foundation
- Malpasso v. Pallozzi is a constitutional challenge to Maryland’s “good and substantial reason” requirement for a firearm carry permit
October 24, 2019 - United States Supreme Court
- FPC Brief in Support of Petitioners (PDF)
- FPC was joined on the brief by Firearms Policy Foundation, Cato Institute, Firearms Policy Coalition, California Gun Rights Foundation, Second Amendment Foundation, Citizens Committee For The Right To Keep And Bear Arms, Jews For The Preservation Of Firearms Ownership, Madison Society Foundation, and Independence Institute
- Worman v. Healey is a constitutional challenge to Massachusetts' ban on "assault weapons" and "high capacity" firearm magazines
October 2, 2019 - United States Supreme Court
- FPC Brief in Support of Petitioners (PDF)
- Guedes v. BATFE is a challenge to Chevron deference and the Trump Administration's unlawful executive fiat ban on "bump-stock type" devices
October 1, 2019 - United States Supreme Court
- FPC Brief in Support of Petitioner (PDF)
- Medina v. Barr is a Second Amendment challenge to federal lifetime ban on firearms as applied to non-violent felons
- Related news release (Oct. 3, 2019)
September 4, 2019 - United States Supreme Court
- Soto v. Remington - Brief in support of petition for writ of certiorari (PDF); related News Release
- FPC and its fellow amici filed a brief explaining that “the exercise of the right to keep and bear arms has always had a relationship to military use of arms,” hence the Second Amendment’s prefatory clause preventing the elimination of the militia. Indeed, throughout the colonial and founding eras, government mandated that most of the free population (often including women) acquire and keep the arms most suitable for militia service.
- The brief provides the history and purpose of the PLCAA, and describes the decades of abusive lawsuits brought by anti-gun cities and states intended to bankrupt the firearms industry. The brief draws parallels between the abusive suits designed to destroy the firearms industry and the abusive suits brought by civil rights opponents throughout the Civil Rights movement, designed to destroy free speech in the Jim Crow South. Just as the Supreme Court halted the abusive lawsuits against the press in the 1960s, Congress enacted the PLCAA to end the abusive lawsuits against the firearms industry.
- FPC’s coalition amicus brief encourages the Supreme Court to restore the PLCAA’s protections of fundamental, individual human rights.
- FPC is joined by amici law professors and Second Amendment scholars Randy Barnett (Georgetown), Royce Barondes (Missouri), Robert Cottrol (George Washington), Nicholas Johnson (Fordham), Joyce Malcolm (George Mason), George Mocsary (Southern Illinois), Joseph Olson (Mitchell Hamline), Glenn Reynolds (Tennessee), Eugene Volokh (UCLA), and Gregory Wallace (Campbell), as well as advocacy organizations Firearms Policy Foundation, Cato Institute, Independence Institute, Madison Society Foundation, and California Gun Rights Foundation (formerly The Calguns Foundation).
August 1, 2019 - United States Supreme Court
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FPC and FPF are joined by SAF and CGF in a Supreme Court brief in support of certiorari in Cheeseman v. Polillo, which seeks to overturn New Jersey's "justifiable need" (i.e., "good cause") requirement that is a de facto ban on law-abiding individuals' fundamental, individual Second Amendment right to carry outside their home.
May 14, 2019 - United States Supreme Court
- NYSRPA, et al. v. City of New York (merits stage) amicus brief
- FPC, FPF, and CGF argue that the "Constitution itself has done the categorizing and those rights covered ‘shall not be infringed.’ Period," and that so-called “tiers” of scrutiny used by courts are a “wholly judicial invention” that “should be viewed with skepticism when applied to conduct directly protected by the constitutional text.”
- Related news release HERE
Feb. 4, 2019 - United States Supreme Court
- Pena v. Horan Supreme Court (cert stage) amicus brief
- Brief filed at the United States Supreme Court in support of a Second Amendment challenge to California's handgun Roster and microstamping requirements that prevent law-abiding people from buying handguns that are in common use for lawful purposes throughout the United States
Dec. 20, 2018 - United States Supreme Court
- Mance v. Whitaker amicus brief
- Brief filed at the United States Supreme Court in support of a Second Amendment challenge to federal gun control laws that prohibit law-abiding people from buying handguns outside of their state of primary residence
Oct. 26, 2017 - United States Supreme Court
- Silvester v. Becerra amicus brief
- Challenge to California's 10-day waiting period
Jan. 15, 2015 - United States Supreme Court
- Teixeira v. County of Alameda amicus brief
- Challenge to County of Alameda gun store ban
Jan. 15, 2015 - United States Supreme Court
- Jackson v. San Francisco amicus brief
- Challenge to San Francisco locked storage
First Circuit
Second Circuit
Third Circuit
December 28, 2021 - Third Circuit Court of Appeals
- Range v. Garland
- Federal lawsuit challenging lifelong gun ban based on a non-violent crime.
- Brief of Amici Curiae Firearms Policy Coalition and FPC Action Foundation in Support of Appellant and Reversal
- Press Release
September 22, 2020 - Third Circuit Court of Appeals
- ANJRPC v. Attorney General of New Jersey Grewal - Brief in Support of Rehearing En Banc
- Lawsuit challenging New Jersey's "large capacity" magazine ban
- FPC's coalition brief argues that American history and tradition prove that the Second Amendment protects so-called "large-capacity" magazines, here.
September 1, 2020 - Third Circuit Court of Appeals
- Amicus Brief cited and argument adopted in dissenting judge's argument
- Third Circuit upheld NJ magazine capacity ban: ruling
- February 03, 2020: Brief in Support of Appellants
- Related news release here.
July 10, 2020 - 3rd Circuit Court of Appeals
- Brief in support of appellants in Drummond v. Township of Robinson
- Drummond argued that the District Court improperly applied heightened scrutiny again, and emphasizing the court’s animus towards the right to keep and bear arms, asked for the case to be reassigned to a different judge on remand.
- FPC and FPF elaborated on the District Court’s poor treatment of the Second Amendment, highlighting the many ways in which the court treated the Second Amendment differently than other enumerated rights.
- Brief was authored by Firearms Policy Coalition (FPC) Director of Research, Joseph Greenlee, lead by FPC, and supported/joined by Firearms Policy Foundation (FPF) and Madison Society Foundation (MSF)
February 3, 2020 - 3rd Circuit Court of Appeals
- ANJRPC v. Attorney General of New Jersey Grewal - Brief in Support of Appellants
- FPC's coalition brief argues that New Jersey's ban on so-called "large-capacity" magazines violates the Second Amendment.
- FPC was joined by amici Professors of Second Amendment Law, Firearms Policy Foundation (FPF), California Gun Rights Foundation (CGF), Second Amendment Foundation (SAF), Madison Society Foundation (MSF), and Independence Institute (II)
July 11, 2019 - Third Circuit Court of Appeals
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FPC and FPF are joined by SAF, FOAC, and MSF in 3rd Circuit Court of Appeals brief in the appeal of USA v. Hunt-Irving supporting appellant's Second Amendment as-applied challenge.
July 1, 2019 - Third Circuit Court of Appeals
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FPC and FPF are joined by SAF, FOAC, and MSF in 3rd Circuit Court of Appeals brief in the appeal of Holloway v. Att'y Gen'l Barr, et al. supporting plaintiff-appellee's Second Amendment as-applied challenge to federal lifetime ban.
June 27, 2019 - Third Circuit Court of Appeals
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FPC and FPF are joined by FOAC and SAF in 3rd Circuit Court of Appeals brief in Folajtar v. Att'y General of the USA supporting appellant's Second Amendment as-applied challenge.
Fourth Circuit
Fifth Circuit
August 1, 2022 - Fifth Circuit Court of Appeals
- Cargill v. Garland
- Challenge to the ATF Final Rule banning bump stocks
- Brief for Amici Curiae Firearms Policy Coalition and FPC Action Foundation Supporting Appellant and Reversal
- Press Release
March 16, 2021 - Fifth Circuit Court of Appeals
- Cargill v. Garland, et al
- Challenge to the ATF Final Rule banning bump stocks.
- Brief of Amici Curiae Firearms Policy Coalition and The Center To Keep and Bear Arms
- Press Release
Nov. 5, 2015 - Fifth Circuit Court of Appeals
- Hollis v. Lynch amicus brief
- Challenge to federal machine gun ban
Sixth Circuit
August 2, 2021 - Sixth Circuit Court of Appeals
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GOA v. Garland: Lawsuit challenging the federal bump stock ban.
- Brief of Amicus Curiae Firearms Policy Coalition in Support of Plaintiffs-Appellants
June 25, 2019 - Sixth Circuit Court of Appeals
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Cato Institute, FPC file amicus brief in 6th Circuit Court of Appeals in the appeal of GOA, et al. v. Attorney General Barr, et al. supporting appellant's challenge to Trump Bump-Stock Ban
Seventh Circuit
May 23, 2022 - Seventh Circuit Court of Appeals
- Atkinson v. Garland
- Challenging lifetime gun ban for non-violent felony conviction
- Brief of Amici Curiae Firearms Policy Coalition and FPC Action Foundation
- Press Release
May 16, 2022 - Seventh Circuit Court of Appeals
- Miller v. Smith
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Lawsuit challenging Illinois law and regulations that ban firearm possession in child care facilities, including home day care facilities and foster family homes
- Brief of Amici Curiae Firearms Policy Coalition and FPC Action Foundation
- Press Release
July 15, 2021 - Seventh Circuit Court of Appeals
- N.J. v. Sonnabend: Lawsuit challenging school bans on clothing that depict firearms.
- Brief of Firearms Policy Coalition and Firearms Policy Foundation as Amici Curiae in Support of Defendants-Appellees
Eighth Circuit
Ninth Circuit
August 28, 2020 - Ninth Circuit Court of Appeals
- Teter v. Connors Amicus brief filed
- Challenging Hawai'i state law
- Butterfly knives are not "dangerous and unusual"
- Butterfly knives should be covered by 2nd Amendment protections
August 10, 2020 - Ninth Circuit Court of Appeals
- Brief in support of Rhode
- Case of Rhode v. Becerra
- Related news release here.
June 4, 2020 - Ninth Circuit Court of Appeals (en banc)
- Young v. Hawaii
- Brief in support of Young
March 19, 2020 - Ninth Circuit Court of Appeals
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United States v. Israel Torres - Brief of Amici Curiae Firearms Policy Coalition, Firearms Policy Foundation, Madison Society Foundation, California Gun Rights Foundation, and Second Amendment Foundation in Support of Appellant’s Petition for Rehearing En Banc
February 3, 2020 - Ninth Circuit Court of Appeals
- Rupp v. Becerra - Brief in Support of Appellants
- FPC's coalition brief argues that California's so-called "assault rifles" statute violates the Second Amendment.
- FPC was joined by amici Firearms Policy Foundation (FPF), California Gun Rights Foundation (CGF), Second Amendment Foundation (SAF), Madison Society Foundation (MSF), and Independence Institute (II)
September 23, 2019 - Ninth Circuit Court of Appeals
- Duncan v. Becerra - Brief in Support of Appellees and Affirmance (PDF); related News Release
- FPC's coalition brief argues that so-called "large-capacity" magazines are inherent components of functional firearms, that such magazines are "in common use" for lawful purposes, and are constitutionally protected.
- FPC was joined by amici individual gun owners: William Wiese, Jeremiah Morris, Lance Cowley, Sherman Macaston, Clifford Flores, L.Q. Dang, Frank Federau, Alan Normandy, and Todd Nielsen, all plaintiffs in the Wiese v. Becerra magazine ban challenge
- FPC was also joined by amici Firearms Policy Foundation (FPF), California Gun Rights Foundation (CGF), Second Amendment Foundation (SAF), Armed Equality (AE), San Diego County Gun Owners (SDCGO), Orange County Gun Owners (OCGO), Riverside County Gun Owners (RCGO), and California County Gun Owners (CCGO)
June 21, 2019 - Ninth Circuit Court of Appeals
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Cato Institute and FPC file joint amicus brief in the appeal of U.S. v. Bronsozian, a case concerning a conviction for failing to pay a tax for a "machinegun" that cannot be paid due to other statutes, arguing that as the Supreme Court has repeatedly found, a tax must be a tax. For a government of enumerated powers to function, those powers must be clearly defined. The fact that a case involves guns—even unpopular guns—is not a reason to smudge the taxing power into a grant to do whatever the government wants.
Nov. 19, 2018 - Ninth Circuit Court of Appeals
- Young v. Hawaii amicus brief
- Right to bear arms outside the home
Dec. 24, 2014 -Ninth Circuit Court of Appeals
- Peruta v. County of San Diego amicus brief
- Challenge to California's carry ban
Tenth Circuit
February 15, 2022 - United States District Court for the District of Colorado
- Sgaggio v. De Young
- Case where the magistrate judge concluded that Sgaggio’s criticism of City of Woodland Park, Colorado government employees was “obscene” and therefore unprotected by the First Amendment
- Motion of Firearms Policy Coalition for Leave to File Brief Amicus Curiae
- Press Release
October 13, 2020 - Tenth Circuit Court of Appeals
- Aposhian v. Barr: bump stock ban appeal to Tenth Circuit en banc panel
- FPC Amicus Brief urging the Tenth Circuit to protect due process and enforce separation of powers by applying Rule of Lenity: here
- Oral arguments
June 13, 2019 - Tenth Circuit Court of Appeals
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Cato Institute, FPC file amicus brief in 10th Circuit Court of Appeals in the appeal of Aposhian v. Attorney General Barr, et al. supporting appellant's challenge to Trump Bump-Stock Ban
Eleventh Circuit
D.C. Circuit
STATE COURTS
Colorado
June 3, 2019 - Colorado Supreme Court
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FPC/FPF file amicus brief in Colorado Supreme Court in support of right of Coloradans to magazines over 15 rounds in capacity
Georgia
February 10, 2021 - Georgia Court of Appeals
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McBrayer, et al. v. The Governors Ridge Property Owners Association, Inc., et al.: Amicus brief arguing that lawful businesses should not be liable for harms caused by the businesses’ adversaries
- Brief Amici Curiae of Law Professors, the Firearms Policy Coalition, and the Georgia First Amendment Foundation
- Press release
Idaho
February 23, 2021 - Idaho Supreme Court
- U.S. v. Gutierrez: FPC filed a brief in support of Mr. Gutierrez, arguing that under the Idaho Constitution, individuals convicted of misdemeanors cannot be prohibited from keeping and bearing arms.
- Amicus Brief
- Press Release
Illinois
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December 6, 2021 - Illinois Supreme Court
- People v. Brown
- Case where the State of Illinois has charged a life-long law abiding woman for keeping a single-shot .22 caliber bolt-action rifle in her home for self-defense because she did not possess a FOID card.
- Brief of Amici Curiae State’s Attorney Stewart J. Umholtz, Professors of Second Amendment Law, Independence Institute, Firearms Policy Foundation, and Firearms Policy Coalition In Support of Defendant-Appellee
- Press Release
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May 31, 2019 - Illinois Supreme Court
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FPC/FPF file coalition brief in Illinois Supreme Court arguing that the FOID law's application to Respondent is unconstitutional
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Maine
December 2, 2019 - Maine Supreme Judicial Court (sitting as the Law Court)
- FPC Brief in Support of Appellant (PDF), joined by Firearms Policy Foundation (FPF)
- In Maine v. Tonini, the Maine Supreme Judicial Court asked three questions:
- Can a person who possesses marijuana be determined to be "an unlawful user of or . . . addicted to any controlled substance" within the meaning of the firearms possession prohibition in 15 M.R.S. § 393(1)(G)?
- What effect, if any, does an acquittal on a charge of furnishing a scheduled drug have on the State's ability to establish that the defendant was prohibited from possessing a firearm pursuant to section 393(1)(G)?
- What is the test for evaluating the constitutionality of section 393 in light of the United States Supreme Court's decisions in District of Columbia v. Heller, 554 U.S.570 (2008), and McDonald v. City of Chicago, 561 U.S. 742 (2010)?
- FPC argued that: 1) Federal precedent indicates that persons similarly situated to the Appellant cannot be determined to be “unlawful users of or . . . addicted to any controlled substance” within the meaning of 18 U.S.C. § 922(g)(3); and, 2) The appropriate test for assessing the Section 393’s constitutionality is an examination of the constitutional text as informed by history, tradition, and public meaning.
Michigan
March 5, 2021 - Michigan Supreme Court
- Wade v. University of Michigan: Lawsuit challenging the University of Michigan’s campus-wide ban on carrying firearms.
- Brief of Amici Curiae Firearms Policy Coalition and Firearms Policy Foundation on Support of Plaintiff-Appellant
- Press Release
Pennsylvania
May 31, 2019 - Pennsylvania Supreme Court
- Commonwealth v. Hicks
- 2017-12-26: FPC/FPF filed a brief by Joshua Prince
- 2019-5-31: Pennsylvania Supreme Court ruled on 'stop-and-frisk of gun owners (Majority, Concurring, Concurring)
Vermont
February 22, 2021 - Vermont Supreme Court
- State v. Misch Opinion
- Brief of Amici Curiae Cato Institute, Firearms Policy Coalition, Firearms Policy Foundation, and Independence Institute in Support of Appellee
- Press Release
- Order on Motion to Reargue
April 24, 2020 - Vermont Supreme Court
- FPC authored and filed a brief in State v. Misch at the Vermont Supreme Court
- The brief, joined by Firearms Policy Foundation, the Cato Institute, and Independence Institute, argues that Vermont’s history and tradition proves that so-called “large capacity” magazines are protected by the Vermont Constitution, and that banning such magazines makes bad policy because they are common and effective arms for defense of self and others.