Published August 12, 2026 at 5:48 PM ET · Updated August 12, 2026 at 6:36 PM ET
Ninth Circuit hands rare Second Amendment win over Hawaii gun rule
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The Ninth Circuit Court of Appeals ruled in favor of a challenge to a Hawaii gun regulation. The decision provides a legal victory for Second Amendment advocates.
Patriot Watch first flagged this story 2 hr ago, when AmmoLand reported it. So far this remains a single-source report. The most recent report came 2 hr ago from AmmoLand.
⚖ The Constitutional Angle
Wolford v. Lopez held Hawaii's law barring licensed carriers from carrying on private property open to the public without express owner authorization violates the Second Amendment, restoring the common-law implied license to enter. Under Bruen, once the text covers the conduct the government must justify its rule by historical tradition, which Hawaii could not.
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