In the second quarter of 2025, the National Rifle Association filed two cert petitions in the U.S. Supreme Court and five amicus briefs, while continuing to litigate dozens of ongoing lawsuits across the country. NRA counsel also published two law review articles, posted a new video in the Legal Scholar Video Series, completed three interviews about current cases, and participated in two webinars to discuss our litigation efforts.
Cert Petitions
In May, we petitioned the Supreme Court to hear NRA v. Glass, our challenge to Florida’s ban on firearm purchases by adults under 21. In March, the en banc Eleventh Circuit upheld the ban in an 8-4 decision, deepening the split among the federal circuit courts. At this point, the Fourth, Tenth, and Eleventh Circuits have upheld restrictions for adults under 21, while the Third, Fifth, and Eighth Circuits have held similar restrictions unconstitutional.
In June, NRA-ILA counsel petitioned the Supreme Court to hear Rush v. United States, a challenge to the National Firearms Act of 1934’s tax and registration requirements for short-barreled rifles. Jamond Rush, an otherwise law-abiding citizen, was convicted of possessing an unregistered AR-15 rifle with a 7.5-inch barrel and sentenced to 30 months’ imprisonment. After the Seventh Circuit upheld the conviction, determining that short-barreled rifles are not even arms, we joined the case to help convince the Supreme Court to hear it and hold the NFA requirements unconstitutional.
Ongoing Litigation
We completed our briefing in the Seventh Circuit in Barnett v. Raoul—our challenge to Illinois’s bans on “assault weapons” and “large-capacity magazines”—and the court scheduled oral arguments on September 22, 2025. Notably, on June 13, the U.S. Department of Justice filed an amicus brief on behalf of the United States supporting our challenge and arguing that the bans violate the Second Amendment.
Duncan v. Bonta is an NRA-backed challenge to California’s prohibition on standard 10+ round magazines. In 2023, a federal district court held that California’s ban violates the Second Amendment. But in March, the en banc Ninth Circuit upheld the ban in a 7-4 decision. The majority concluded that magazines are “accessories” rather than “arms,” and even if they were arms, the ban is consistent with historical regulations that prohibited “especially dangerous uses of weapons.” The four dissenting judges argued that the ban is unconstitutional. The petition seeking the Supreme Court’s review was originally due June 18, but after an extension, it is now due July 18.
On May 13, the Tenth Circuit heard oral arguments in Ortega v. Grisham, our challenge to New Mexico’s 7-day waiting period for firearm purchases.
In response to the NRA’s landmark victory in NYSRPA v. Bruen, several states enacted “Bruen-response” laws, labeling dozens of locations throughout the state “sensitive places” where carry is forbidden. Maryland enacted one such law. We challenged this law in the Maryland District Court in Kipke v. Moore. On August 2, 2024, the court held unconstitutional the carry ban at buildings on private property unless the owner expressly provides permission; locations selling alcohol (including bars and restaurants); and property within 1,000 feet of a public demonstration. But the court upheld the rest of the ban. Both the government and we appealed the decision to the Fourth Circuit. We completed the briefing on appeal in February, and the court heard oral arguments on May 7, 2025.
In LaFave v. County of Fairfax, the NRA-backed challenge to Fairfax County’s ban on carrying firearms in county parks, the briefing was completed in January and the Fourth Circuit heard oral arguments on May 7, 2025.
We filed the reply in support of our preliminary injunction motion in Young v. Ott—our challenge to Pennsylvania’s ban on concealed carry by adults under 21—and the district court scheduled a trial on October 6, 2025.
Our challenge to the ATF’s “engaged in the business” rule, Butler v. Bondi, resumed after being stayed for several months while the Trump Administration reconsidered the government’s approach in the case. The parties filed their cross-motions for summary judgment in the district court, while several states (New Jersey, Arizona, Colorado, Connecticut, Delaware, Hawaii, Maryland, Michigan, Minnesota, Nevada, North Carolina, Oregon, Rhode Island, Vermont, and Washington) moved to intervene in the case.
In our challenge to the BLM’s ban on recreational shooting in the Sonoran Desert National Monument, U.S. Sportsmen’s Alliance Foundation v. U.S. Bureau of Land Management, the government received a 60-day extension to file its answer to our complaint, so that the new Administration can evaluate the challenged resource management plan and determine how they wish to proceed.
Amicus Briefs
The NRA filed an amicus brief urging the Supreme Court to hear a challenge to the federal lifetime prohibition on firearms possession by nonviolent felons. The case, Vincent v. Bondi, was brought by Melynda Vincent, who is forever prohibited from possessing a firearm based on a 2008 felony conviction for submitting a fraudulent $498.12 check to a grocery store. Our brief argues that there is no historical justification for disarming peaceable citizens and that the ban therefore violates the Second Amendment as applied to nonviolent felons.
The NRA filed an amicus brief in Beckwith v. Frey, a case challenging Maine’s 72-hour waiting period on firearm purchases. The brief, filed in the First Circuit, argues that the Second Amendment protects the right to acquire arms and that there is no tradition of regulation that supports a mandatory “cooling off” period for all firearm purchases.
The NRA also filed an amicus brief arguing that the federal prohibition on machinegun possession is unconstitutional as applied to the defendant in the Fifth Circuit case, United States v. Brown. The brief emphasizes that by focusing on policy arguments rather than historical tradition, the government failed to carry its burden of proving that the ban is consistent with our nation’s historical tradition of firearm regulation.
The NRA filed another amicus brief in Gun Owners of America v. Philadelphia, a challenge to Philadelphia’s prohibition on the private manufacture of firearms. The brief argues that any regulation of firearms or ammunition—including their parts and components—by local governments is preempted by Pennsylvania’s Uniform Firearms Act, Pennsylvania’s constitution, and public and legislative reliance.
NRA filed its fifth amicus brief this quarter—and tenth of the year—in Wolford v. Lopez, a challenge to Hawaii’s law requiring concealed-carry permitholders to obtain consent from property owners before carrying in ordinary public places such as restaurants, gas stations, and grocery stores. The brief urges the Supreme Court to hear the case and emphasizes that Hawaii’s law was deliberately designed to make public carry so impractical that citizens choose not to exercise their rights.
Other Firearms-Related Litigation Across the Country
In Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos—the Mexican government’s lawsuit attempting to hold American firearm manufacturers liable for cartel violence in Mexico—the U.S. Supreme Court held in a unanimous 9-0 decision that the Protection of Lawful Commerce in Arms Act barred the suit because Mexico failed to plausibly allege that the manufacturers aided and abetted unlawful sales to Mexican traffickers.
The Supreme Court denied certiorari in Snope v. Brown, a challenge to Maryland’s “assault weapons” ban. Justices Thomas, Alito, and Gorsuch voted to hear the case. Justice Kavanaugh did not, but he expressed that he expects the Court to hear a challenge to an “assault weapons” ban within the next term or two.
Legal Scholar Video Series
In the latest installment of the NRA’s Legal Scholar Video Series, NRA-ILA Litigation Director Joseph Greenlee interviewed historian and constitutional scholar Joyce Lee Malcolm. The interview examines the political and religious conflicts of seventeenth-century England—including the English Civil War and the Glorious Revolution—that led to the inclusion of a right to arms in the 1689 English Bill of Rights, which later influenced the Second Amendment to the U.S. Constitution.
Articles
NRA-ILA Litigation Director Joseph Greenlee and then-NRA President Bob Barr published an article in the Penn State Dickinson Law Review entitled, When Rights Require Permission: The Discriminatory History of Licensing Laws for Firearm Possession. The article explores the historical tradition of regulations requiring a permit to possess firearms and applies the Supreme Court’s test to determine whether modern permitting laws violate the Second Amendment.
Greenlee also published an article in the University of Wyoming Law Review entitled, The Tradition of Short-Barreled Rifle Use and Regulation in America. The article: (1) describes many short-barreled rifles from the nineteenth century and their predecessors from the colonial and founding eras; (2) analyzes the historical regulations relevant to short-barreled rifles; and (3) applies the Supreme Court’s Second Amendment doctrine to modern regulations on short-barreled rifles.
Interviews
NRA counsel completed three interviews about our current cases. Greenlee joined Frank Miniter of America’s 1st Freedom to discuss the NRA’s amicus brief filed in Lowy v. Daniel Defense. And he joined American Family Radio to discuss Barnett v. Raoul, our challenge to Illinois’s ban on “assault weapons” and “large-capacity magazines.” Erin Erhardt spoke with Arms Room Radio to provide a general overview of NRA’s ongoing litigation.
Webinars
NRA counsel participated in a webinar in May to discuss our litigation efforts in New Jersey, and another webinar in June to discuss our litigation efforts in Washington.
Please stay tuned to www.nraila.org for future updates on NRA-ILA’s ongoing efforts to defend your constitutional rights, and please visit www.nraila.org/litigation to keep up to date on NRA-ILA’s ongoing litigation efforts.
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