In re D.L.
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The juvenile court found that at a 2020 neighborhood party, 17-year-old D.L. shot and killed a six-year-old boy and shot an adult twice. Video footage showed D.L. running down a hill seconds after the shooting, stumbling, and then running. Officers recovered a handgun in a dirt-filled hole where D.L. had stumbled. DNA swabbed from the handgun was a match with D.L.’s DNA. D.L. admitted to several felonies prior to the incident, including assault, robbery, and theft in 2018, and burglary in 2019. D.L. appealed his conviction for possession of a loaded firearm in San Francisco. (Pen. Code 25850(a)), arguing that under the U.S. Supreme Court’s 2022 “Bruen” holding section 25850 must be facially unconstitutional based on its relationship to California’s laws for obtaining a concealed-carry license.
The court of appeal affirmed. Before Bruen, California required an applicant for a concealed carry license to show “good cause,” usually by establishing a specific need to carry a gun for self-defense. D.L. argued that the requirement was substantially similar to the “proper cause” requirement for a New York unrestricted firearm license, struck down in Bruen. California’s “good cause” requirement did not survive Bruen but is severable from the other requirements for obtaining a concealed carry license, saving California’s regulatory framework for gun possession and preserving D.L.’s conviction.
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