Term: 2019
Docket: 18-280
New York State Rifle & Pistol Association Inc. v. City Of New York, New York
- Pro
18-280 NEW YORK STATE RIFLE & PISTOL ASSN., INC. V. CITY OF NEW YORK DECISION BELOW: 883 F.3d 45 CERT. GRANTED 1/22/2019 QUESTION PRESENTED: New York City prohibits its residents from possessing a handgun without a license, and the only license the City makes available to most residents allows its holder to possess her handgun only in her home or en route to one of seven shooting ranges within the city. The City thus bans its residents from transporting a handgun to any place outside city limits-even if the handgun is unloaded and locked in a container separate from its ammunition, and even if the owner seeks to transport it only to a second home for the core constitutionally protected purpose of self-defense, or to a more convenient out-of-city shooting range to hone its safe and effective use. The City asserts that its transport ban promotes public safety by limiting the presence of handguns on city streets. But the City put forth no empirical evidence that transporting an unloaded handgun, locked in a container separate from its ammunition, poses a meaningful risk to public safety. Moreover, even if there were such a risk, the City's restriction poses greater safety risks by encouraging residents who are leaving town to leave their handguns behind in vacant homes, and it serves only to increase the frequency of handgun transport within city limits by forcing many residents to use an in- city range rather than more convenient ranges elsewhere. The question presented is: Whether the City's ban on transporting a licensed, locked, and unloaded handgun to a home or shooting range outside city limits is consistent with the Second Amendment, the Commerce Clause, and the constitutional right to travel. LOWER COURT CASE NUMBER: 15-638
The case of New York State Rifle & Pistol Association Inc. v. City of New York, 2019 revolved around a challenge to the city's regulation that restricted licensed handgun owners from transporting their firearms outside the city limits. The plaintiffs argued that this rule violated their Second Amendment rights and sought an injunction against its enforcement. However, after the lawsuit was filed, both the city and state amended their gun control regulations to allow for more freedom in transportation of firearms by licensed owners - effectively rendering moot the original issue brought before court by petitioners. As such, when it reached Supreme Court review in 2020, they ruled unanimously that because these changes had been made to law during litigation process itself (which now allowed what was previously prohibited), there were no longer grounds for adjudication or relief as requested originally by petitioners; thus dismissing case as 'moot'. This decision did not address any broader issues related to Second Amendment rights or gun control laws.
In the dissenting opinion for New York State Rifle & Pistol Association Inc. v. City of New York, Justice Sonia Sotomayor, joined by Justice Ruth Bader Ginsburg, argued that the case was moot and should not have been heard by the Supreme Court because NYC had already amended its regulation to allow licensed gun owners to transport their firearms to second homes or shooting ranges outside city limits. The justices contended that hearing a moot case goes against traditional judicial restraint and could be seen as an indication of eagerness on part of some members of the court to rule on Second Amendment cases. They also expressed concern about how this decision might encourage litigants in future cases to behave similarly - changing laws after they've been challenged in order to preserve favorable lower-court rulings while avoiding review from higher courts.
