Hanson v. District of Columbia, No. 23-7061 (D.C. Cir. 2024)
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The appellants, Andrew Hanson and others, challenged the District of Columbia's law that limits firearm magazine capacity to 10 rounds. They argued that this restriction violates their Second Amendment rights, particularly in light of the Supreme Court's decision in N.Y. State Rifle & Pistol Ass’n v. Bruen, which emphasized historical traditions of firearm regulation over means-end scrutiny.
The United States District Court for the District of Columbia denied the appellants' motion for a preliminary injunction. The court conducted a renewed analysis under the Bruen framework, which involves determining whether the Second Amendment covers the conduct in question and, if so, whether the regulation is consistent with historical traditions. The district court found that while extra-large capacity magazines (ELCMs) are "arms" under the Second Amendment, their possession is not protected because they are not typically used for lawful purposes. Additionally, the court held that the District's magazine cap is consistent with historical firearm regulations aimed at reducing violence.
The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that ELCMs are "arms" under the Second Amendment and are in common use for self-defense. However, it found that the District's magazine cap is consistent with historical regulations of weapons that posed unprecedented lethality, such as Bowie knives and machine guns. The court also noted that the regulation addresses the modern societal concern of mass shootings, which did not exist at the time of the Founding.
The court concluded that the appellants failed to demonstrate a likelihood of success on the merits or irreparable harm. It emphasized the importance of maintaining the status quo and the potential public safety risks of enjoining the magazine cap. Therefore, the court affirmed the district court's denial of the preliminary injunction.
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