Published September 24, 2026 at 1:47 PM ET · Updated September 24, 2026 at 2:45 PM ET
Hawaii's 'vampire' gun restrictions survive another Ninth Circuit round
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Hawaii's gun restrictions, referred to as 'vampire' restrictions, survived another round of review in the Ninth Circuit Court of Appeals. The outcome leaves the restrictions in place for now.
Patriot Watch first flagged this story 6 d ago, when Instapundit reported it. So far this remains a single-source report. The most recent report came 6 d ago from Instapundit.
⚖ The Constitutional Angle
Wolford v. Lopez is the Hawaii template: the Supreme Court struck down Hawaii's rule barring licensed carry on private property open to the public absent express permission. Bruen supplies the governing test: once plain text covers public carry for self-defense, Hawaii must justify any restriction with historical tradition. A circuit round keeping a rule alive is not final; that history still must be shown.
Jason Wolford v. Anne E. Lopez, Attorney General of Hawaii 609 U.S. ___ (2026) (slip op.); U.S. Reports page not yet assigned
Vote: 6-3 · Opinion: Alito
Hawaii's law (Haw. Rev. Stat. § 134-9.5(a) (2023)) prohibiting licensed concealed-carry permit holders from carrying handguns on private property open to the public without the owner's express authorization violates the Second and Fourteenth Amendments. The decision restores the common-law default: a person lawfully carrying enjoys the implied license to enter property held open to the public unless the owner withdraws consent — a State may not flip that default to require express permission.
New York State Rifle & Pistol Association v. Kevin P. Bruen, Superintendent of New York State Police 597 U.S. 1 (2022)
Vote: 6-3 · Opinion: Thomas
New York's requirement that applicants demonstrate 'proper cause' — a special need for self-protection distinguishable from the general community — to obtain an unrestricted public-carry license violates the Fourteenth Amendment by preventing law-abiding citizens with ordinary self-defense needs from exercising their Second Amendment right to keep and bear arms in public. The Court held the Second Amendment protects a right to carry handguns publicly for self-defense, and rejected the two-step means-end framework lower courts had applied after Heller.
Precedent facts from the PW Law Library — primary-source verified & independently audited
