The Supreme Court's 2022 holding in New York State Rifle & Pistol Association Inc. v. Bruen, was expected to shake up gun laws across the country. And it has. 

The Bruen decision requires the constitutionality of state gun laws to be evaluated based upon the country's “historical tradition of firearm regulation.” In Baird v. Bonta, a resident of Northern California challenged the state's law prohibiting him from openly carrying firearms in counties with at least 200,000 residents, which amounts to a ban for 95% of the state's population. Mr. Baird argued that the law ran afoul of the Second Amendment and Bruen because openly carrying weapons is a “historical practice” that cannot be outlawed by today's lawmakers. In a 2-1 decision, the Ninth Circuit agreed, with the two Judges appointed by President Trump striking down the law, and the Judge appointed by George W. Bush upholding it. It is expected that a larger panel of Ninth Circuit Judges will agree to hear the case and possibly override the ruling through the en banc rehearing process.

This ruling is emblematic of the confusing state of gun laws since Bruen was decided. As I posted earlier this month, I expect the rights of gun owners to be the subject of a number of major decisions in 2026. I will be following them closely. Stay tuned.