New York State Rifle & Pistol Assn., Inc. v. City of New York

Background

Three New York City gun owners and a gun-rights organization sued to stop a City rule that barred people with home handgun licenses from taking their guns to shooting ranges or a second home outside the city. The lower courts rejected their challenge, and the group asked the high court to review whether the rule violated the Second Amendment. After review was granted, New York State changed its law and the City amended the rule so licensees may now travel to out-of-city ranges and second homes under a requirement that trips be "direct."

Reasoning

The Court concluded the original request for an injunction against the old City rule is moot because the City and State changes provide the precise relief the plaintiffs sought. The Court therefore vacated the appeals-court judgment and remanded the case to the lower courts for further proceedings. The Court did not decide the underlying constitutional Second Amendment question. Instead, it left unresolved whether the new rule’s limits on "direct" travel permit routine stops like coffee, gas, food, or restroom breaks, and whether the plaintiffs may still add a late claim for damages arising from the old rule.

Real world impact

Licensed New York City gun owners can now travel to ranges and second homes outside the city under the new rule, but the meaning of "direct" travel and what stops are allowed remains unclear. The case returns to lower courts to sort out those questions and to decide whether plaintiffs may pursue damages for past enforcement of the old rule, so the issue is not finally decided.

Dissents or concurrances

A concurring justice agreed with the procedural result and urged broader attention to how lower courts apply Heller and McDonald. A dissenting justice argued the case was not moot, would have decided the merits for the plaintiffs, and emphasized possible damages and attorney-fee implications.