High Impact Status

Decided — 9th Cir. No. 21-16756, published en banc opinion filed Sept. 22, 2026 (Owens, J.). REVERSED AND REMANDED. Official slip (SoT): https://cdn.ca9.uscourts.gov/datastore/opinions/2026/09/22/21-16756.pdf. The en banc court reversed the D. Haw. injunction that had blocked two features of Hawaii's shall-issue handgun-acquisition regime. Current § 134-2(e): a permit to acquire a pistol or revolver is void unless used within thirty days (amended up from the old ten-day window; a void permit means the applicant restarts). Current § 134-3: inspection is no longer universal; fn. 1 limits it to private-party transfers, certain self-manufactured or 3D-printed firearms, and firearms brought into Hawaii. Holding: under Bruen footnote 9, objective non-abusive shall-issue regimes are presumptively constitutional, and plaintiffs failed to show these two provisions have been put toward abusive ends. Quote: they "impose only modest, procedural burdens, and do not materially impede Plaintiffs from acquiring firearms." The same opinion says lengthy wait times, exorbitant fees, and other shall-issue components can still trigger the right. Not a Cal. Penal Code holding. Not a carry holding. Not a cert grant. Panel opinion Yukutake v. Lopez, 130 F.4th 1077 (9th Cir. 2025), is vacated, 144 F.4th 1119 (9th Cir. 2025) — do not cite the panel. District: D. Haw. 1:19-cv-00578-JMS-RT (Seabright, J.); Yukutake v. Conners, 554 F. Supp. 3d 1074 (D. Haw. 2021). Argued and submitted March 24, 2026, Pasadena. Lineup is 11 judges. Nelson, J., dissents, joined by Bress and VanDyke and, except Part I-C, by Bade and Forrest (Forrest would affirm on the merits and narrow relief under Trump v. CASA). Separate VanDyke dissent. That is the reported 6-5. X is secondary. Distinct from Elite Precision Customs v. ATF (HI #83) — do not merge.

This is binding Ninth Circuit law as of Sept. 22, 2026, and it is a loss. Do not cite the vacated 2025 panel. California will quote "do not materially impede" and the footnote 9 line that a shall-issue rule is presumptively lawful unless the challenger proves abusive ends. That quote will be aimed at ten-day waits, DROS, private-party paperwork, and inspection or registration conditions. Use the majority's own limit: the opinion says lengthy wait times, exorbitant fees, and other shall-issue components can still trigger the Second Amendment. Hawaii's thirty-day use-it window and narrowed inspection were held modest. A scheme that actually delays, prices, or denies people is the "abusive ends" opening, not this holding. Do not let the State move Bruen's burden onto the client just because it calls the scheme shall-issue. Nelson is the brief: plain text covers acquisition, footnote 9 is about public-carry licensing rather than a safe harbor for purchase rules, and the government still owes a historical analogue. Wolford does not erase this opinion — the majority cites Wolford's skepticism of Hawaii and still upholds these two rules. Not a holding on the California Penal Code, and not an injunction a California client can ride. Cert has not been filed.

Decided — 5th Cir. No. 25-11206, published opinion filed Sept. 18, 2026 (Smith, J.; Haynes, J., dissenting). Panel REVERSED N.D. Tex. 4:25-CV-44 (Pittman, J.) dismissal and RENDERED judgment for plaintiffs. Holding: 18 U.S.C. §§ 922(a)(3), 922(a)(5), and 922(b)(3) — the Nonresident Handgun Purchase Ban — violate the Second Amendment under Bruen. Official slip (SoT): https://www.ca5.uscourts.gov/opinions/pub/25/25-11206-CV0.pdf (Doc. 83-1). GOA-hosted PDF is a copy. Mandate, stay of mandate, and ATF implementing guidance not observed as of this update. United States is a party (ordinary FRAP 40 rehearing window 45 days unless shortened). En banc and cert remain possible; 2d Cir. went the other way in Vereen. Statutes remain on the books. Not Ninth Circuit law. Not a nationwide operational repeal of interstate handgun FFL sales. Distinct from HI #109 (OLC 922(b)(1)/(c)(1) 18–20 dealer sales), Reese (18–20 dealer-sale holding; cited here only for purchase-as-keep), Howeth (HI #89), and Silencer Shop (HI #20). GOA X is secondary.

Do not tell a California client they can walk into an out-of-state FFL and leave with a handgun. This is a published Fifth Circuit holding, not Ninth Circuit law. Mandate, stay of mandate, and ATF guidance were not observed as of this update. 18 U.S.C. §§ 922(a)(3), (a)(5), and (b)(3) remain on the books. California roster, 10-day wait, DROS, and PC 27545 FFL-only transfer rules are untouched. Immediate uses: (1) In the Fifth Circuit (TX/LA/MS), newly decided published authority that the Ban is unconstitutional — use for dismissal or continuance in pending § 922(a)(3)/(a)(5) prosecutions, with an explicit caveat that mandate has not been observed and rehearing/en banc/cert are live. (2) Portable acquisition-right language: Reese's 'right to keep and bear arms surely implies the right to purchase them,' plus the panel's holding that an FFL-to-FFL fee-and-delay workaround does not take a purchase ban outside Bruen Step 1. That travels to CA waiting-period, FFL-only, and roster arguments — the government must justify a purchase-channel restriction with a historical analogue, not modern convenience. (3) Step 2: colonial export / Indian-trade / wartime / proofing laws are the wrong why/how for peacetime civilian interstate sales (Hemani lower generality; Nguyen v. Bonta cited on a lost Dutch-era analogue). (4) Circuit split with Vereen (2d Cir.) is the cert vehicle, not a CA holding. Fence: not OLC #109 (age 922(b)(1)/(c)(1)); not Reese's 18–20 dealer-sale invalidation; not Howeth #89 (Denver carry); not Silencer Shop #20 (NFA). GOA X 2101069326111617399 is secondary; cite the official slip. Portable fee line (Fifth Circuit published; not Ninth Circuit law): Smith, J., slip 8–9 — prior-circuit hints of an “acceptable cost” on the basic exercise of Second Amendment rights are “abrogated by Bruen and its progeny” (fn. 5, Bezet’s $200 transfer tax under means-end scrutiny). Use as persuasive authority that a fee-and-delay FFL workaround, or a modest tax on acquisition, is not self-justifying. Still not a holding that California’s 10-day wait, DROS fee, or roster is invalid, and not advice that a California client may buy a handgun from an out-of-state FFL.

Open

Direct CA 9th Cir. challenge to under-21 acquisition/possession restrictions; strong Bruen framing usable in any CA under-21 or age-based denial motion.

District final judgment — D.N.M. 1:24-cv-00471-JB-SCY (Browning, J.). Docs 126–127 filed Aug. 27, 2026: plaintiffs' MSJ GRANTED; defendants' MSJ DENIED; N.M. Stat. § 30-7-7.3 enjoined as to plaintiffs Ortega and Scott only (immediate). Final Judgment entered; docket terminated. Not statewide. Binding circuit law remains Ortega v. Grisham, 148 F.4th 1134 (10th Cir. Aug. 19, 2025); en banc denied Dec. 22, 2025. Appeal window open.

Controlling 10th Cir. authority against categorical waiting/cooling-off periods (148 F.4th 1134). On remand, Judge Browning granted plaintiffs' MSJ and entered plaintiff-only permanent injunctive relief because 'an inferior court has no power or authority to deviate from the mandate' — even though he 'continues to believe the Waiting Period Act is constitutional.' Do not tell a court that New Mexico's wait is off the books for everyone; the injunction runs only to Ortega and Scott. Use: (1) the circuit quotes on acquisition and temporary deprivation; (2) the mandate/law-of-the-case holding when a trial court tries to relitigate a published 2A reversal at the merits stage; (3) pair immediately with RMGO v. Polis (HI #75/#67, CO 3-day under advisement) and Beckwith v. Frey (HI #39, cert pending on the 1st Cir. split). Portable to CA 10-day (PC 26815/27540).

Permanent injunction in effect (N.D. Tex. Aug. 5, 2026; stay expired Aug. 12; operational Aug. 13). CBS News (Lynch/Jacobs, Sept. 17, 2026): sources say President Trump ordered DOJ not to appeal Hendrix; a DOJ official said the department intends to tell Congress it will not appeal; ATF spokesperson said ATF "will issue guidance soon to implement the court's order." Not a PACER notice of non-appeal. FRAP appeal window still open through Oct. 5, 2026. Party-specific (plaintiffs, current/future members and customers). Not a nationwide NFA repeal. Formal national ATF guidance still outstanding. Prior: Cekada non-enforcement as characterized by SAF Aug. 31.

Highest current practical value for federal NFA possession, constructive possession, Form 1/4, and registration-based charges involving now-untaxed items. Direct utility in California federal cases. Membership/customer protection language expands the protected class. Completed August 13 unregistered suppressor transfers convert the holding from paper injunction to demonstrated operational fact. Still party-specific — do not claim automatic nationwide coverage. Pair with common-use / historical-tradition authorities; not a Bruen merits judgment. Already mapped to Motion Bank 210 (Case Watch), 211 (Modular Block), and 214 (Form 1 / private-making extension). Montana files: identify whether the count is federal NFA, a state analogue that still uses non-registration / tax-stamp as an element, or both. Verify Hendrix coverage (plaintiff org member or customer) before arguing the injunction as a shield. Use the Knudsen letter as charging-discretion and incorporation evidence, not as a dismissal holding. Do not advise that unregistered suppressors or SBRs may be possessed with impunity. California: portable enumerated-powers / registration-hook framing; not a CA statutory template. Bank: 210/211/214 already mapped — Data polish for state-analogue charging language. New (Buzz 258 / Tang 2026-08-31): Cekada's non-enforcement statement is usable as charging-discretion / implementation evidence for covered parties (plaintiffs, members, customers of organizational plaintiffs) and FFLs processing unregistered post-tax-zero NFA items. Quote SAF as secondary until a signed ATF guidance memo exists. Do not tell uncovered clients they are safe. Anecdotal local ATF contacts after Aug. 13 do not override the injunction for covered persons, and they do not expand coverage. Verify Hendrix coverage (member/customer) before using as a shield. New (CBS 2026-09-17 / Tang 2026-09-18): No-appeal posture is now reported by CBS from a DOJ official, an ATF spokesperson, and unnamed administration sources — not from GOA/Clyde X. Use as charging-discretion / implementation evidence for Hendrix-covered parties only. Verify membership or customer status before arguing the injunction as a shield. Do not tell uncovered clients they are safe. Do not claim the NFA is repealed nationwide. Prohibited-person statutes and machine-gun/destructive-device NFA remain. Silmon (M.D. Ala.) is one charging example, not a circuit holding. Until a notice of non-appeal is on the N.D. Tex. docket or the Oct. 5 window closes without a filing, treat "will not appeal" as administration posture, not a final appellate waiver. Formal ATF guidance still outstanding.

Pending. Bonta motion to intervene (Doc. 47; FRCP 5.1/24(a) and 28 U.S.C. § 2403; facial constitutionality of fee and psych-exam statutes only) remains UNDECIDED. Noticed for hearing Sept. 17, 2026, 9:00 AM, San Jose Courtroom 4 before Judge Davila. As of 2026-09-17 ~07:03 PT: no ECF minute entry of held, continued, submitted, granted, or denied. CourtListener RECAP last event is a Sept. 9, 2026 Clerk's Notice (body not retrieved this run). Judge Davila public calendar (https://apps.cand.uscourts.gov/CEO/cfd.aspx?7143, last updated Sept. 17, 2026 7:03 AM) lists the judge UNAVAILABLE on Thursday, Sept. 17, 2026 and does not list 5:25-cv-08027. Do not write a hearing outcome. Do not tell a court the motion was granted or denied. Status conference Aug. 4, 2026 (Davila, J.): parties to meet and confer on amended complaint/schedule and to contact Chief Magistrate Judge Cousins before the then-noticed Sept. 17 hearing. Subsequent RECAP events without bodies here: Aug. 20 stipulation and proposed order (Doc. 53); Sept. 1 appear-by-telephone (Doc. 54). Distinct from United States v. City of San Jose (HI #107) — do not merge.

Directly addresses the two most common practical barriers California public defenders encounter when clients seek lawful carry: extreme permitting costs and mandatory psychological screening. Provides ready framing for fee challenges and psych-exam challenges that can be adapted to other counties. The limited nature of Bonta’s intervention supplies useful language distinguishing state statutory authorization from local policy choices. Do not cite a Sept. 17, 2026 grant or denial of intervention — none is on ECF. Keep distinct from San Jose (HI #107).

Open — N.D. Cal. 5:26-cv-10508-SVK. Complaint filed Sept. 16, 2026 (Doc. 1, 14 pages) by the United States against the City of San Jose and the San Jose Police Department. Assigned to Magistrate Judge Susan van Keulen. Consent/declination due Sept. 30, 2026. Counsel: Harmeet K. Dhillon (AAG, Civil Rights), Barry K. Arrington (Chief, DOJ Second Amendment Section), Patrick Todd and Tristan Silva II (trial), Craig H. Missakian (U.S. Attorney). Single claim: 34 U.S.C. § 12601(a) pattern-or-practice of enforcing an allegedly exorbitant CCW application fee of $1,591 (San Jose Res. No. 2026-183; 20%/$318 up front, $1,273 at issuance) plus SJPD-policy psychological testing with the cost on the applicant (not required by Cal. Penal Code § 26190(e)). Prayer: declaration and permanent injunction against abusive licensing fees. Not a holding. Not an injunction. The fee and testing remain in force. Distinct from Blank v. Santa Clara (HI #14) (private CRPA/SAF challenge to Santa Clara County fees/psych exam) — do not merge. Distinct from United States v. LASD (HI #29) (CCW processing delays, settled) — do not merge.

Immediate California vehicle for fee and psych-exam arguments in CCW counseling and in any paper that has to explain why a client could not complete a shall-issue application. Quote Bruen 597 U.S. at 38 n.9 ('exorbitant fees deny ordinary citizens their right to public carry') and the complaint's comparison set. Do not cite as a holding. Do not tell a court the fee has been enjoined. Pair Blank (HI #14) for the private-plaintiff / statewide-statute (PC 26190) overlay and United States v. LASD (HI #29) for the § 12601 enforcement template. Official complaint: https://storage.courtlistener.com/recap/gov.uscourts.cand.479057/gov.uscourts.cand.479057.1.0.pdf. Docket: https://www.courtlistener.com/docket/74798613/united-states-v-san-jose/.

Open — district stay LIFTED July 15, 2026. C.D. Cal. In Re Senate Bill 2 Litigation, 8:23-cv-01696-MRA-ADS (Ramírez Almadani, J.) (May lead; Carralero 8:23-cv-01798 consolidated then terminated into that docket July 16, 2025). Official ECF 85 (in chambers): stay lifted, case REOPENED (JS-5); parties to file a Proposed Schedule of Pretrial Dates Worksheet. ECF 87 (July 24) extended that worksheet to Aug. 21, 2026. ECF 89 (Aug. 21) joint status report — May plaintiffs and Bonta propose reopening expert discovery (Bonta supplemental reports by Oct. 16, 2026; plaintiff rebuttals Nov. 16; expert cutoff Dec. 16) in light of Wolford and Hemani. No new trial date set on this pass. Prior stay was ECF 79 (Oct. 14, 2025) pending Wolford. Ninth Circuit Nos. 23-4354 (Carralero) and 23-4356 (May) remain on the 2024 PI appeal track; 9th Cir. panel opinion Sept. 6, 2024 (partial location-ban relief). Not a holding that SB 2 is invalid. SB 2 location bans and licensing expansions remain in force except to the extent of any unstayed injunction. Wolford v. Lopez (SCOTUS June 2026) is the frame, not a ruling in this case. Distinct from Novotny (HI #27) and LASD settlements (HI #28/#29). CRPA member email recapping the lift is secondary to ECF 85.

Core California public-carry / location-ban vehicle. Use for any CA client charged in a gun-free zone, an SB 2 location, or a CCW-condition case. Quote the live 9th Cir. posture and Wolford's daily-life carry holding as the frame CRPA is using — do not tell the court that Wolford already invalidated SB 2. The Sept. 1, 2026 DOJ bulletin (2026-DLE-14, CRPA characterization) is immediate counseling material for CCW-renewal delays, new fingerprinting, DOJ-clearance lag, and lapse-risk; it is implementation, not a merits win. Pair with Novotny (HI #27) for the post-Wolford location-ban theory and with LASD delay settlements (HI #28/#29) for processing. Do not merge May into Novotny or into the LASD settlements. Core California public-carry / location-ban vehicle. Use for any CA client charged in a gun-free zone, an SB 2 location, or a CCW-condition case. Quote ECF 85 (stay lifted, case reopened) and Wolford's daily-life carry holding as the frame CRPA is using — do not tell the court that Wolford already invalidated SB 2, and do not treat a member email as the order. The Sept. 1, 2026 DOJ bulletin (2026-DLE-14, CRPA characterization) is immediate counseling material for CCW-renewal delays, new fingerprinting, DOJ-clearance lag, and lapse-risk; it is implementation, not a merits win. Pair with Novotny (HI #27) and LASD delay settlements (HI #28/#29). Do not merge.

Open — W.D.N.Y. 1:26-cv-01718-LJV. Complaint filed Aug. 13, 2026 (Doc. 1) by The Firing Pin, LLC, Lucas Nelson, Daniel J. Geary, NRA, FPC, and SAF against NY AG Letitia James, NYSP Superintendent Steven G. James, and DAs Callanan (Wayne), Green (Monroe), and Finnell (Genesee). NEW (Doc. 26, filed Sept. 11, 2026): Answer by defendant Brian P. Green, Monroe County District Attorney (official capacity; Monroe County Attorney). Not a merits ruling. Not an injunction. New York's Glock / Glock-style sales ban remains in force. Distinct from United States v. California (HI #78) (CA Glock-platform / AB 1127) and Bathras v. Moore (HI #26) (MD Glock) — do not merge.

Near-perfect parallel to CA roster + AB 1127 issues. Fresh common-use language on cruciform-trigger handguns is immediately useful for CA acquisition defenses. Near-perfect parallel to CA roster + AB 1127 / Glock-platform issues. Fresh common-use language on cruciform-trigger handguns will be useful for CA acquisition defenses IF and when the court rules. Doc. 26 is a county-DA answer, not authority. Do not cite the answer as a holding. NY ban remains in force. Do not tell a CA client the NY case enjoins anything.

Open — 5th Cir. No. 26-10302 (from N.D. Tex. 4:24-cv-01049). District court (N.D. Tex.) upheld Tex. Penal Code § 46.03(a)(4) racetracks, (a)(7) 51%-alcohol businesses, and (a)(8) sporting/interscholastic events March 24, 2026. Appellee brief + court-appointed amici (Eric Ruben / Gregg Costa) filed Aug. 14, 2026; policy amici (Everytown, Texas Restaurant Association, Houston Astros et al., Houston Livestock Show and Rodeo, Harris County) filed Aug. 21, 2026. NEW (Sept. 11, 2026): Plaintiffs-Appellants’ Reply Brief filed (FPC tracker Doc. 094). FPC characterizes Director Freeman Martin as agreeing the challenged bans are unconstitutional while seeking jurisdictional dismissal so DPS can keep enforcing them. That is a party-position claim in a brief, not a holding and not a concession order. Not a Fifth Circuit decision. § 46.03(a)(4), (7), and (8) remain in force. Distinct from Novotny v. Moore (HI #27) and May/Carralero (HI #52) — do not merge.

Direct authority for Texas public defenders handling UCW or place-restricted carry charges under § 46.03(a)(4), (7), or (8). Provides ready Bruen framing and Fifth Circuit development on alcohol-premises, stadium, and event bans. Portable to other jurisdictions’ similar location restrictions. Texas § 46.03(a)(4)/(7)/(8) charges remain live. Use the pending 5th Cir. appeal (reply now on file) for continuance/stay language in Texas location-ban prosecutions, and as portable Bruen framing for California SB 2 alcohol-serving, amusement, and sports-venue counts — analog only. Do not cite the reply, the DPS-Director characterization, or the policy amici as a holding. Quote the filed brief if used at all.

Cert granted June 30, 2026 — consolidated merits (Nos. 25-238 VIDED 25-566). Official SCOTUS docket 25-238 (rechecked 2026-09-10): last proceeding is Sept. 9, 2026. Petitioners' merits brief and joint appendix SUBMITTED Aug. 28, 2026. Counsel of record David H. Thompson, Cooper & Kirk. Respondents' merits briefs due Oct. 21, 2026 (July 15 extension). SET FOR ARGUMENT on Wednesday, December 2, 2026. VIDED. 1 hour. October Term 2026. Not a decision. United States amicus in support of petitioners remains on the docket (Sept. 4). NEW (official docket Sept. 9, 2026): Motion of United States of America for leave to participate in oral argument and for divided argument SUBMITTED. Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423604/20260909144515105_25-238%20Viramontes%20Divided%20Argument%20Motion.pdf. Not granted. Not a holding. Fence: FPC X recaps (2097003171650445328; 2098080538208686476) are secondary and restate the Sept. 4 wave plus this motion. Do not treat the motion as argument time awarded. Do not label Oct. 21 as a United States brief — Oct. 21 remains respondents Cook County et al. Rule 37.3 amici supporting respondents due Oct. 28, 2026. Petitioners' reply TBD.

Defenders handling assault-weapon, feature-ban, or AR-15 cases should cite the dual cert grants (Nos. 25-238 & 25-566, June 30, 2026) when seeking stays, continuances, or extensions — the law is unsettled nationwide. Petitioners' opening merits brief and joint appendix are on the official docket (submitted Aug. 28, 2026). Quote the filed brief, not X threads. SAF public PDF: https://saf.org/wp-content/uploads/2026/08/Viramontes-opening-brief-8.28.26.pdf. Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/25-238.html. Respondents' briefs due Oct. 21, 2026 remains a longer continuance/stay hook. Motion Bank already has a stay/continuance block (motion 123) keyed to the grants + McDonald v. Katz (HI #13). New (docket Sept. 4, 2026) — argument is set. Cite official language: SET FOR ARGUMENT on Wednesday, December 2, 2026. VIDED. Stay, continuance, and extension papers can now point to a firm argument date, not only the June 30 grants. Respondents still due Oct. 21, 2026. New (docket Sept. 4, 2026) — THE United States amicus. Cover: BRIEF FOR THE UNITED STATES AS AMICUS CURIAE IN SUPPORT OF PETITIONERS. Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423192/20260904171730387_25-238GovtAmicusBr.pdf. Counsel of record D. John Sauer, SG. Docket clerk line is only 'Amicus brief of United States of America submitted' — cover controls the support direction. Amicus of the Executive, not a holding of the Court. Stay papers may note the United States has now told the Court that categorical AR-15 bans violate the Second Amendment; quote the filed brief, not X. Fence: Rocky Mountain Gun Owners and Gun Owners of America are both named Sept. 4 amici. Do not keep any 'GOA unfiled' or 'RMGO unfiled' line. GOA coalition official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423106/20260904132250217_Viramontes%20Amicus%20final.pdf. USCCB and Amar are neither-party (cover); do not harvest as petitioner AWB authority. All listed amici are not holdings. Motion 123 remains the bank vehicle. Do not mint a twin. Do not write the bank from this seat. New (docket Sept. 4, 2026; captured Buzz 269) — CRPA / Duncan / Rupp coalition amicus. Cover: IN SUPPORT OF PETITIONERS. Counsel of record C.D. Michel, Michel & Associates. Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423130/20260904140014849_2026-09-04%20Viramontes_Grant%20Amicus%20Brief%20re%20CRPA.pdf. Named amici include Virginia Duncan and Steven Rupp (California LCM / AWB plaintiffs). The brief asks the Court to say its reasoning will govern Duncan, and to grant and summarily reverse Duncan or give guidance that requires reversal. Amicus, not a holding. Not a grant in Duncan. Quote the filed brief, not X. California AWB/LCM stay and continuance papers may note that the Duncan and Rupp plaintiffs have told this Court the AWB merits vehicle should control those cases; they may not treat Duncan or Miller as reversed. New (docket Sept. 4, 2026; captured Buzz 269) — Tennessee, Kansas, and 25 other States amicus. Cover: IN SUPPORT OF PETITIONERS. Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423107/20260904132345610_25-238%2025-566%20Amici%20Brief.pdf. Amicus, not a holding. Stay papers may note 27 States have told the Court that AR-15-platform rifles are in common use for lawful purposes; quote the filed brief. New (Buzz 270; official docket rechecked 2026-09-08) — no post-Sept. 4 proceeding. Continuance/stay papers may now cite the remaining briefing window through respondents' Oct. 21, 2026 merits briefs and Rule 37.3 respondent-side amici due Oct. 28, 2026, with argument still set Dec. 2, 2026. Fence: do not tell a court that 'the government brief is due Oct. 21.' The United States already filed as amicus IN SUPPORT OF PETITIONERS (Sept. 4). Oct. 21 is respondents Cook County et al. FPC X 2097003171650445328 is secondary. CGRF/Danielle Jaymes/Use of Force Experts amicus (official PDF locked) is not a holding and is not a Glock-ban ruling; quote the filed brief if used at all. Motion 123 remains the bank vehicle. Do not mint a twin. New (official docket Sept. 9, 2026; Buzz 273) — United States motion for leave to participate in oral argument and for divided argument SUBMITTED. Clerk line: 'Motion of United States of America for leave to participate in oral argument and for divided argument submitted.' Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-238/423604/20260909144515105_25-238%20Viramontes%20Divided%20Argument%20Motion.pdf. Not granted. Stay/continuance papers may note that the United States has now asked to argue the AWB merits vehicle; they may not tell a court that the Solicitor General has been allotted time. Quote the docket line, not X. Motion 123 remains the bank vehicle. Do not mint a twin.

Final judgment entered Aug. 18, 2026 (ECF 331; opinion ECF 330 dated Aug. 17, 2026) (N.D. Tex., O’Connor, C.J.). Declaratory relief and permanent injunction in effect as written. As of 2026-09-11 CourtListener/RECAP check: no docket entry after ECF 331; no notice of appeal of this judgment; no motion to stay this judgment. FRAP 4(a)(1)(B) 60-day clock (United States a party) still open (~Oct. 17, 2026). Fifth Circuit No. 26-10244 is Defense Distributed’s March 18, 2026 appeal of an earlier order (district ECF 302) — DD appellant, government appellee; last CL entry Aug. 7, 2026 (appellee brief). That docket is not an appeal of ECF 330/331. Not SCOTUS. Not nationwide vacatur.

Lead with the declaration for a verified current or future SAF member charged under the 2022 Frame & Receiver Rule — that shield is not product-limited. The permanent injunction is the second, narrower shield and only matches the four named DD kits. Independent 2A and vagueness reasoning is citable as N.D. Tex. persuasive authority even outside the covered set, but it is not an injunction for non-members and is not Ninth Circuit law. Do not tell a California PMF / PC 29180 client that the federal rule is vacated nationwide; the CFR text remains on the books as to everyone else. Do not treat Bondi as undone — SCOTUS already upheld the rule on APA/statutory grounds; this is the constitutional remand only. Do not merge with Rigby v. Jennings (HI #100, Delaware unserialized/self-manufacture bans) or FPC v. Blanche (HI #44, post-office carry; same AG name, different docket). Verify SAF membership before asserting coverage. Motion Bank 215 (case watch) and 216 (modular) already encode this hierarchy and remain accurate on these docket facts — no bank rewrite from this check.

Open (en banc)

High utility for as-applied challenges to 922(g); potential Commerce Clause arguments in federal felon-in-possession cases. Portable to CA and other circuits for dangerousness and historical tradition arguments under Rahimi/Bruen.

Open (9th Cir en banc ordered after panel win on urban open-carry ban; panel opinion vacated)

Open-carry and licensing scheme. En banc posture makes it high-signal for any open-carry, urban-ban, or shall-issue vs may-issue argument in CA.

Live — 3d Cir. Nos. 24-2415, 24-2450 & 24-2506. En banc opinion July 17, 2026 struck New Jersey's assault-weapons ban and large-capacity magazine ban. District: D.N.J. 1:22-cv-04360. Caption now Cheeseman v. Davenport (formerly Platkin). Mandate stayed Aug. 4, 2026 pending SCOTUS. NEW (Buzz 267): FPC reported Sept. 3, 2026 that New Jersey told the Third Circuit it is 'working diligently on their petition for certiorari and plan to file well in advance of the October 15, 2026 deadline' (90 days from the July 17 opinion). Not a SCOTUS petition. No SCOTUS docket number. Not a grant. NJ AWB/LCM remain in force under the stay. Distinct from Viramontes/Grant (HI #1) (already granted). X (gunpolicy 2095548701410238543) is secondary; the 3d Cir. letter was not independently pulled from PACER this run. FPC tracker: https://www.firearmspolicy.org/cheeseman.

Highest portable circuit-level AWB and LCM merits language currently available for California PC 30600 / 32310 practice. Cite the en banc opinion, not the cert-prep letter. Motion Bank already has the harvest vehicle (motion 124). The Sept. 3 letter is a watch item only: if New Jersey files, Cheeseman becomes a second-state SCOTUS AWB/LCM vehicle behind the already-granted Viramontes/Grant pair (HI #1). Do not treat the October 15 deadline as a filed petition. Do not cite the mandate stay as invalidating New Jersey or California bans. Pair with Viramontes stay/continuance language (motion 123) when asking a CA court to pause AWB/LCM counts — Viramontes is the granted vehicle; Cheeseman is the strongest posted appellate merits win still stayed.

Open — Cross-SJ oral argument held Aug 24, 2026 before Judge Kane (D. Colo.); taken under advisement; written decision pending. PI previously denied; law remains in effect. Primary 10th Cir. authority: Ortega v. Grisham (HI #77).

Strong portable value for acquisition-delay / waiting-period challenges. Directly engages 10th Circuit Ortega precedent striking NM 7-day wait; judge’s unusually detailed agenda signals potential resistance to that precedent and creates clean issues for appeal. Useful parallel language for CA 10-day (Richards) and similar temporal barriers.

Open — Sacramento Superior Court; FPC-backed; Amended Complaint filed; MSJ noticed for hearing ~August 25, 2026; Answer filed August 20, 2026

Pure California case. Directly attacks an acquisition-cost barrier. Strong language available on special taxation of constitutional rights. Immediate practical relevance for any CA client or dealer facing the tax or arguing downstream effects on the right to acquire.

Open

Clean under-21 carry vehicle. Holdings on age-based restrictions and 'the people' travel directly to CA under-21 acquisition and carry arguments.

Open / ongoing

Strong Bruen-response and location-ban framing. Useful for any CA sensitive-places or post-Bruen licensing challenge.

Open

Confiscatory LCM language highly portable to CA PC 32310 possession/transfer arguments and any standard-capacity magazine case.

Open

Statewide (beyond Cook County) AWB + LCM vehicle. Provides additional framing on feature bans and magazines that travels to CA defenses.

Open / related to Duncan posture

LCM possession and acquisition. Complements Duncan; useful for any client charged under PC 32310 or facing magazine restrictions.

Open

Primary CA AWB challenge. Holdings on common-use and historical tradition for feature bans are portable across CA AWB prosecutions and related civil challenges.

Open

Classic acquisition-delay vehicle. Directly useful for any CA client facing waiting-period criminal exposure or for motions attacking temporal barriers to the right to acquire arms.

Open

Strong portable framing for under-21 acquisition challenges; useful for CA defenders arguing age-based restrictions lack historical analogue, and for C&R collector issues in federal cases.

Motion filed August 13, 2026 by C.J. Grisham. Client charged with Unlawful Carry of a Weapon for open carrying a handgun in a vehicle without a holster.

Clean state-constitutional attack on a common technical restriction. Immediate utility for Texas defenders handling UCW / vehicle-carry cases. Portable framing for any jurisdiction that imposes holster, “secure,” or similar conditions on open or vehicle carry.

Preliminary injunction granted statewide on June 25-26, 2026 by Judge John Martin. Injunction runs until December 31, 2026 or final order. State planning appeal. Judge ruled individual plaintiff John Crump has standing; GOA and VCDL lacked standing in this ruling.

Excellent source of statutory interpretation arguments (vague/feature-based definitions, charging defects) that pair well with models like Massachusetts Lacus. Provides detailed briefing on state constitutional history and Bruen-aligned analysis. Useful for building VA-specific argument blocks and attacking both sale/transfer bans and public carry restrictions.

Preliminary injunction denied June 18, 2026 (Judge William E. Glover). Case ongoing. Ban allowed to take effect in jurisdiction initially.

Strong state constitutional challenge using the Militia Clause theory - a creative and potentially portable approach for states with similar militia-tethered right-to-arms language. High strategic value for Research Engine (historical/militia analysis, state constitutional interpretation post-Bruen) and future motion drafting (PI standards, standing via militia membership, facial vs. as-applied challenges to feature-based bans).

Cert pending — SCOTUS No. 26-255 (docketed Aug. 27, 2026). Petition filed Aug. 24, 2026 (Ryan Morrison, Liberty Justice Center). Response due Sept. 28, 2026. Respondent waived response Aug. 31, 2026. DISTRIBUTED for Conference of Sept. 28, 2026 (entered Sept. 2, 2026). Court has not requested a response. Not a grant. Lower: 8th Cir. No. 25-3036, 176 F.4th 1055 (May 26, 2026) (affirmed dismissal; held Minn. Stat. § 624.714, subd. 16 does not restrict arms-bearing conduct at Bruen step one). District: D. Minn. 25-cv-54, 804 F. Supp. 3d 927 (Sept. 11, 2025) (McCoy and Johnson v. Jacobson). Minnesota reciprocity statute remains in force. Distinct from Calce v. City of New York (HI #99) (response requested Sept. 8 after waiver) — waiver-plus-distribution is not a requested response. Distinct from Howeth (HI #89) (Denver/Colorado stacked-statute complaint). NEW (official docket Sept. 15, 2026): Amicus brief of Second Amendment Foundation, National Rifle Association of America, California Rifle & Pistol Association, Second Amendment Law Center, Minnesota Gun Owners Caucus, and Citizens Committee for the Right to Keep and Bear Arms SUBMITTED. Counsel of record Konstadinos T. Moros. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-255/424260/20260915115457667_26-255%20Second%20Amendment%20Foundation%20brief%20-%20KTM%20approved%20PDF.pdf. Still petition-stage. Conference of Sept. 28 stands. Waiver Aug. 31 stands. Not a grant. Amicus, not a holding. NEW (official docket Sept. 22, 2026; Buzz 288): Separate amicus brief of Huang Tiange and Corey Biazzo SUBMITTED. Counsel of record Corey John Biazzo, Biazzo Law PLLC. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-255/425274/20260922224415240_Huang%20Biazzo%20Brief.pdf. Individual travelers, not an organization brief, and not the Sept. 15 SAF/Moros brief. The Buzz line "at least two briefs" overcounts: one new filing covers both named amici. Court still has not requested a response. Waiver Aug. 31 stands. Conference of Sept. 28 stands. Not a grant. Minn. Stat. § 624.714, subd. 16 remains in force. X (Moros 2102600582934765612) is secondary.

Portable traveler / non-reciprocity authority for any client arrested while carrying on a valid out-of-state CCW in a state that does not honor it — including California clients traveling and travelers into California (pair Hoffman v. Bonta HI #56 and Duvall v. Maryland HI #69). Do not cite as a win: the Eighth Circuit is adverse, cert is not granted, and the Court previously turned away Gardner on similar traveler facts. Immediate uses: (1) continuance/stay hook while 26-255 is pending in reciprocity prosecutions; (2) contrast language — the Eighth Circuit said non-reciprocity 'does not restrict any arms-bearing conduct,' which is the government's likely Bruen step-one line in CA nonresident-carry and traveler cases; (3) Bruen n.9 'trust but verify' once a person is already licensed, not a rolodex of state licenses. SAF coalition amicus is ON the docket as of Sept. 15, 2026 (Moros of record) — quote the filed brief if used at all; still not a grant. Official petition: https://www.supremecourt.gov/DocketPDF/26/26-255/419936/20260824142412427_No.%20%20Petition.pdf. Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26-255.html. New (official docket Sept. 2, 2026; captured Buzz 273) — DISTRIBUTED for Conference of Sept. 28, 2026. SoT is the SCOTUS docket, not X. Moros 2097727140792074466 (Sept. 9) is secondary commentary (long-conference timing; amicus-in-support practical advice). The Court has still not requested a response. Do not cite as a grant. Do not tell a court the petition is likely to be denied; long-conference distribution after a waiver is a calendar fact only. Continuance/stay hook in traveler-reciprocity prosecutions is now the Sept. 28 conference, not merely 'response due Sept. 28.' Watch the order list. If a Justice later requests a response, that is a different docket event (see Calce HI #99). Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26-255.html. New (official docket Sept. 15, 2026) — SAF/NRA/CRPA/SALC/MNGOC/CCRKBA amicus is ON the docket (submitted). Lift the prior line that the SAF amicus was 'forthcoming' and 'not on the docket; do not cite as filed.' Quote the filed brief if used at all. Do not cite as a win: Eighth Circuit remains adverse; Gardner remains the caution; conference of Sept. 28 is still the calendar fact, not a grant. Continuance/stay hook in traveler-reciprocity prosecutions is unchanged: Sept. 28 conference + now a filed supporting amicus. Pair bank #148 (Obergefell for Guns — rights do not stop at the state line) when the traveler module is opened. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-255/424260/20260915115457667_26-255%20Second%20Amendment%20Foundation%20brief%20-%20KTM%20approved%20PDF.pdf. Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26-255.html. New (official SAF/NRA/CRPA/SALC/MNGOC/CCRKBA amicus, captured Buzz 280 / 2026-09-17). Argument I heading: 'Travelers From Other States Were Historically Exempted from State and Local Restrictions on Carrying Firearms.' Quote-ready history: 1686 East Jersey exempted 'all strangers, travelling upon their lawful occasions thro' this Province, behaving themselves peaceably'; 1813 Ky. Acts 100, 'unless when travelling on a journey.' Amici: traveler's-exception laws are 'more well-represented' than the surety/affray analogues used in Rahimi, 602 U.S. at 698; Bruen n.9 may allow a state's own shall-issue permit but a state 'may not refuse to honor the permits issued by other states.' CA overlay in Argument II (pp. 15–16): nonresident carry still costs 'anywhere between about $500 and $2,000, depending on the county and city'; PC 26165(a)(1) 16-hour training; some agencies require a psych exam under PC 26190(e); two-year renewal PC 26220(a); n.5 cites Blank v. Santa Clara (HI #14). Pair United States v. City of San Jose (HI #107) on the same 26190(e) psych/fee theory. Amicus, not a holding. Eighth Circuit remains adverse. Conference of Sept. 28 stands. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-255/424260/20260915115457667_26-255%20Second%20Amendment%20Foundation%20brief%20-%20KTM%20approved%20PDF.pdf. New (official Huang/Biazzo amicus, Sept. 22, 2026; Buzz 288). Distinct from the Sept. 15 SAF traveler's-exception brief already on this row. Amici say three points were not developed the same way in the petition or other amici: (1) the Second Amendment is a uniform national right of the people and does not change at a state line — text, history, and Fourteenth Amendment incorporation; interstate comity and Article IV citizenship (Saenz v. Roe) do not shrink it; (2) Bach v. Pataki, 408 F.3d 75 (2d Cir. 2005), Peterson v. Martinez, 707 F.3d 1197 (10th Cir. 2013), and Culp v. Raoul, 921 F.3d 646 (7th Cir. 2019) are not post-Bruen answers — Bach's premise was rejected in McDonald, Peterson was a concealed-carry-only pre-Bruen case, and Culp used means-end scrutiny; (3) this is a clean pleading-stage step-one vehicle: McCoy's dismissal after Minnesota added Texas shows selective reciprocity is unstable, and the Court can correct the framework without deciding every licensing question. Pair Hoffman v. Bonta (HI #56) for travelers into California. Amicus, not a holding. Eighth Circuit remains adverse. Do not cite as a grant. Do not tell a court Minnesota has been asked to respond. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-255/425274/20260922224415240_Huang%20Biazzo%20Brief.pdf.

Cert pending — SCOTUS No. 26-258 (docketed Aug. 27, 2026). Petition filed Aug. 25, 2026 (Erin E. Murphy, Clement & Murphy). Response due Sept. 28, 2026. Linked application 25A1424 (Jackson, J., extended the filing deadline to Aug. 31, 2026). Lower: 1st Cir. No. 25-1160, judgment April 3, 2026 (upheld Maine’s 72-hour cooling-off law); D. Me. 1:24-cv-384 (PI granted Feb. 13, 2025). Not a grant. NEW (official docket Sept. 22, 2026; Buzz 288): Amicus brief of Second Amendment Foundation and National Rifle Association of America SUBMITTED. Counsel of record Konstadinos T. Moros; Joseph G.S. Greenlee for NRA-ILA. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-258/425185/20260922140518490_2026-09-22%20Brief%20of%20SAF%20and%20NRA.pdf. Asks the Court to grant certiorari or, at least, GVR to correct the First Circuit's step-one holding that a waiting period does not implicate the Second Amendment unless it is "abusive." Not a grant. Response due Sept. 28, 2026 still stands. Maine's 72-hour law remains in force. Amicus, not a holding. X (2AFDN 2102516637375340751) is secondary.

Waiting-period / acquisition-delay authority is portable to California’s own waiting-period and processing-delay arguments (including CCW and transfer timelines). Useful for “shall-issue” and temporal-burden framing under Bruen. Direct portable authority for California’s 10-day wait (PC 26815/27540) and any cooling-off / acquisition-delay argument. Cite as a pending cert petition presenting the Ortega split — not as a holding, and not as a grant. The QP plus the 1st Cir.’s ‘acquisition is outside the text unless abusive’ theory is the stay/continuance hook in waiting-period cases; pair immediately with Ortega (HI #77) and RMGO v. Polis (HI #75/#67). Do not tell a court that SCOTUS has granted or decided this. New (official SAF/NRA amicus, Sept. 22, 2026; Buzz 288). Not a grant. Do not cite as a holding that Maine's 72-hour wait, or California's 10-day wait (PC 26815/27540), is invalid. Use only as a filed cert-stage brief on the Ortega split already on this row. Quote-ready from the brief, not from X: the First Circuit held there is no explicit right to acquire a firearm and that a claim is not viable "unless plaintiffs demonstrate that the Act is abusive toward Second Amendment rights," and called the 72-hour law "a burden on, but not an infringement." Amicus cite: Beckwith v. Frey, 171 F.4th 560, 570 (1st Cir. 2026). That reporter pin is from the brief's table of authorities, not re-pulled from a reporter this pass. Amici: that standard puts interest-balancing back in at step one; plain text is not meant to be a difficult hurdle; a delay implicates the right. They cite Elite Precision Customs (HI #83), slip op. at 6: conduct either implicates the plain text and gets a presumption, or it does not. Relief asked: grant, or at least GVR, so Bruen applies when a law "burdens those wishing to exercise" the right (Wolford v. Lopez, 146 S. Ct. 2032, 2047 (2026)). History point, adopting the petition and Ortega: "Until the 1990s, no waiting period law required a prospective buyer to wait longer than was necessary to conduct a background check," Ortega v. Grisham, 148 F.4th 1134, 1150 (10th Cir. 2025). Founding-era retail advertisements in the brief are offered to rebut a "guns were not readily available, so use the nuanced approach" expert story. Cite the brief; they are not trial exhibits. California overlay inside the brief: Nguyen v. Bonta, 140 F.4th 1237, 1245 (9th Cir. 2025) (mass availability is not new); and a Sacramento superior-court minute order in Poway Weapons & Gear v. CDTFA (HI #73) treating an 11% gun-and-ammunition tax as outside the plain text. That minute order is the amicus's example of a plain-text dodge, not a holding to cite as authority. Fence: the brief cites the Yukutake panel, 130 F.4th 1077. The en banc court vacated that panel the same day (HI #110). Do not cite 130 F.4th 1077. Official PDF: https://www.supremecourt.gov/DocketPDF/26/26-258/425185/20260922140518490_2026-09-22%20Brief%20of%20SAF%20and%20NRA.pdf.

Open — complaint and a motion for a temporary restraining order and preliminary injunction filed Sept. 21, 2026, in the District of Connecticut. Caption used by FPC and Buzz 287: Glock Inc. v. Griffin. CourtListener: https://www.courtlistener.com/docket/74823996/glock-inc-v-griffin/ (page not opened this pass; HTTP 403). District docket number not confirmed. A company-style release reposted Sept. 21, 2026 (Smyrna, Ga.) describes the defendants as the Connecticut State's Attorneys and the Commissioner of Emergency Services and Public Protection, and the statute as 2026 HB 5043 / Public Act 26-41 banning "convertible pistols." The act PDF was not opened this pass — do not treat that public-act number as verified from the bill text. SAF (Sept. 21): the complaint seeks a declaration that current Glock models fall outside the new machine-convertible-pistol definition, plus a Second Amendment claim. The same release adds a vagueness claim as to pistols manufactured after Oct. 1, 2026, and a broader Second Amendment claim against banning the class. Not a holding. Not an injunction. The Connecticut ban remains in force unless a court says otherwise. Distinct from United States v. California (HI #78), Bathras v. Moore (HI #26), and The Firing Pin v. James (HI #19) — do not merge.

Do not cite this for a holding. It is the manufacturer-side sibling of the California Glock-platform case (HI #78) and the New York and Maryland convertible-pistol suits (HI #19, HI #26). Watch it for how a court treats "convertible pistol" vagueness and whether redesigned models sit outside the definition — the same fight California will press under the Glock ban and roster conditions. Do not tell a California court that Connecticut has been enjoined. Do not merge the complaints.

OLC memorandum opinion for the Attorney General, dated Sept. 17, 2026, signed T. Elliot Gaiser, AAG, Office of Legal Counsel. Official PDF: https://www.justice.gov/olc/media/1461811/dl. Advice, not a judicial holding. Not a nationwide injunction. 18 U.S.C. §§ 922(b)(1) and 922(c)(1) remain on the books. OLC concludes those provisions 'may not be enforced to impose criminal penalties on dealers who sell handguns' to otherwise law-abiding 18-to-20-year-olds. Opinion does not address § 922(x) (under-18), § 922(t)(1)(C) (under-21 NICS investigative period), § 922(g), or sales to persons under 18. Fn. 14: states are not bound; lists Cal. Penal Code § 27505 among other state age floors. State 21+ acquisition and carry statutes remain in force unless a court said otherwise. Distinct from PWGG v. Bonta (HI #41) (CA under-21 acquisition) — do not merge. Distinct from Roache (HI #87), Pool (HI #88), Brown (HI #98), Meyer (HI #63), and the FPC v. ATF tracker stub (HI #42) — do not merge.

Do not tell a California 18–20 client they can walk into an FFL and buy a handgun. Cal. Penal Code §§ 27505 / 27510 remain in force; OLC fn. 14 says states are not bound. This is federal charging advice, not CA law and not Ninth Circuit law. Immediate use: (1) Federal 922(b)(1)/(c)(1) dealer-sale or straw-adjacent cases involving an 18–20 transferee — DOJ's own OLC says criminal penalties against the dealer for that class of sale may not be imposed; move to dismiss or seek declination, and put the slip opinion in the packet. (2) CA under-21 acquisition (PWGG #41) and 21+ CCW (PC 26150(a)(2) / 26155) — persuasive only: Wolford three-question 'the people' analysis, militia-at-18 history, and the 26th Amendment line quoted from Worth, 108 F.4th at 691 (Benton, J.). (3) Do not cite as wiping § 922(x), § 922(t) waits, or § 922(g). Pair with Reese (5th Cir. holding on the same federal statutes) and distinguish Roache (HI #87) (adverse D. Haw. acquisition/gift judgment).

Pre-suit — Civil Rights Division Notice of Suit dated Sept. 17, 2026, signed by AAG Harmeet K. Dhillon. Noticed caption: United States v. State of Minnesota, City of Minneapolis, and City of St. Paul. Addressed to Gov. Tim Walz, Mayor Jacob Frey, and Mayor Kaohly Her; cc Minnesota AG Keith Ellison, Minneapolis City Attorney Kristyn Anderson, St. Paul City Attorney Irene Kao. Contact: Barry K. Arrington, Chief, Second Amendment Section (barry.arrington@usdoj.gov). Pre-suit deadline: Sept. 23, 2026, 5:00 p.m. ET; if no response, 'the United States may file its complaint without further notice.' CourtListener D. Minn. civil filings Sept. 16–18, 2026 show no matching complaint. Not a filed lawsuit. Not a holding. Not an injunction. Minn. Stat. §§ 624.7131, 624.7132, and 624.714 remain in force. Distinct from Johnson v. Jacobson (HI #84) (non-reciprocity / § 624.714 subd. 16, SCOTUS 26-255) — do not merge. Distinct from United States v. City of San Jose (HI #107) (filed § 12601 CCW-fee complaint) — do not merge.

Portable waiting-period / permit-to-purchase vehicle, not a Minnesota or California charge win and not a filed case. Direct for MN PDs on §§ 624.7131/624.7132 files. For California: pair Richards v. Bonta (HI #51) (CA 10-day, PC 26815/27540), Ortega (HI #77) (controlling 10th Cir. quotes the letter itself cites), RMGO v. Polis (HI #75) (CO 3-day), and Beckwith v. Frey (HI #39) (SCOTUS 26-258 on a 72-hour wait). Quote the United States' litigating position — Bruen 597 U.S. at 38 n.9 ('lengthy wait times in processing license applications … deny ordinary citizens their right to public carry') and Ortega 148 F.4th at 1143 ('[A]cquiring, purchasing, and possessing firearms is a necessary predicate to keeping and bearing them') — as DOJ's own framing, not as a holding in this matter. Do not tell a court a complaint has been filed. Do not tell a court Minnesota's wait has been enjoined. Continuance/stay language in waiting-period or PTP prosecutions can note that DOJ has authorized a § 12601 complaint and set a Sept. 23, 2026 response deadline; that is a calendar fact only. Pair San Jose (HI #107) for the § 12601 template. SoT is the three-page Sept. 17 letter posted by AAG Dhillon, not X commentary: https://x.com/AAGDhillon/status/2100665398706180519.

Cert pending — SCOTUS No. 26-46 (docketed July 10, 2026). Petition filed July 7, 2026 (David H. Thompson, Cooper & Kirk). City of New York waived response Aug. 6, 2026. GOA et al. amicus Aug. 7; Byrna Technologies et al. amicus Aug. 10. Distributed for the Conference of Sept. 28, 2026 while the City had waived; Response Requested Sept. 8, 2026, due October 8, 2026. Lower court: 2d Cir. No. 25-861-cv, summary order April 13, 2026 (Parker, Lohier, Merriam), affirming S.D.N.Y. (Ramos, J.) grant of defendants’ cross-MSJ. N.Y. Penal Law § 265.01 and N.Y.C. Admin. Code § 10-135 remain in force.

This is the live *Caetano* / common-use-at-step-one vehicle. Response due October 8, 2026. Pair Viramontes (#1) and NAGR v. Lamont (#36). Fence: New York’s stun-gun ban is still in force. Not a grant. The Second Circuit disposition is a summary order — not circuit law. Cite in stay and continuance papers: the Court has called for a response on whether *Caetano* still controls a Bruen step-one common-use summary-judgment path. Quote *Caetano* and the filed petition. Revisit when the BIO files or cert is granted or denied.

SUPERSEDED / RETIRED — live tracker is HI #99 (Calce v. City of New York, SCOTUS No. 26-46). Official docket: Response Requested Sept. 8, 2026; due October 8, 2026. This row was distributed for the September 28, 2026 conference while the City had waived; that conference date is stale.

Live Calce card is #99. Response due October 8, 2026. Fence: this row is retired; the Sept. 28 conference date is stale.

Open — 1st Cir. No. 25-1918. Appeal from D. Mass. 1:21-cv-10960 (Casper, J.) (filed as Granata v. Healey). District opinion/judgment Aug. 29, 2025: court rejected the challenge to Massachusetts' Approved Firearms Roster and AG handgun-sales regulations (FPC characterizes the opinion as approval of the MA handgun ban; district terminated that date). Notice of appeal Sept. 24/26, 2025. Fully briefed. United States amicus (Jan. 28, 2026) supporting appellants and urging reversal; unopposed motion to participate in oral argument (Aug. 5, 2026). ARGUED Wednesday, Sept. 9, 2026, 9:30 a.m., En Banc Courtroom, 7th Floor, Boston, before Barron, Gelpí, and Rikelman (appellants/amicus 15 min, appellees 15 min); submitted; opinion pending. Not a holding. Massachusetts roster and AG sales regulations remain in force. Pair Renna v. Bonta (HI #50). Harvest only if/when the panel opinion issues — do not harvest from a missing opinion. Distinct from Recchia v. Campbell (HI #70) (1st Cir. MA AWB, decided) and Lawson v. Campbell (HI #81) (D. Mass. nonresident LTC delays) — do not merge.

Portable roster/feature-gate authority for California UHA/roster practice (Renna v. Bonta, HI #50), not a Massachusetts-only curiosity. Cite for: (1) the live First Circuit vehicle attacking a state approved-handgun roster after a district loss; (2) the United States' amicus urging reversal (Jan. 28, 2026) and sharing argument time; (3) oral argument completed Sept. 9, 2026 (Barron, Gelpí, Rikelman); submitted; opinion pending. Do not cite as invalidation of any California roster rule. Do not treat argument as a holding. Do not merge with Recchia v. Campbell (HI #70) or Lawson v. Campbell (HI #81). Harvest only if/when the opinion issues. Pair with Renna.

Open — D.N.J. lead 1:24-cv-07098-KMW-MJS (Williams, J.; Skahill, M.J.), consolidating Struck (originally 3:24-cv-09479). Caption now Matthew Struck, Daniel Francisco, Firearms Policy Coalition, Inc., and National Rifle Association of America v. Jennifer Davenport (Attorney General) and Jeanne Hengemuhle (NJSP Superintendent); Platkin and Callahan substituted out under Fed. R. Civ. P. 25(d). NEW (Docs. 91-1 and 91-2, filed Sept. 14, 2026): Struck/FPC/NRA plaintiffs' motion for summary judgment and statement of material facts, seeking a declaration that N.J.S.A. § 2C:58-3(i) and N.J.A.C. § 13:54-1.9 (one handgun per 30-day period) are unconstitutional and a permanent injunction against enforcement. Motion date on the SMF caption: December 15, 2026. Same-day Benton plaintiffs' MSJ (Doc. 92-4) on the consolidated docket. Not a holding. Not an injunction. 2C:58-3(i) and 13:54-1.9 remain in force. Distinct from Lopez v. Los Angeles (HI #58) (CA municipal 1-in-30) — do not merge. Distinct from Cheeseman / ANJRPC v. Davenport (HI #59) (NJ AWB/LCM) — do not merge. Ninth Circuit Nguyen v. Bonta (CA statewide 1-in-30; FPC's cited analogue) is not a ruling in this case.

Portable acquisition-rationing vehicle, not a California charge win. Direct for New Jersey PDs on 2C:58-3(i) / 13:54-1.9 files. For California: pair with Lopez v. Los Angeles (HI #58) (LA/Inglewood municipal 1-in-30, still in force) and with Nguyen v. Bonta (9th Cir. statewide 1-in-30 analogue cited in the MSJ — quote Nguyen, not this motion, if used in a CA paper). Do not cite Struck as invalidating any rationing statute. Do not tell a court New Jersey has been enjoined. Continuance/stay language in NJ (and analogously in CA municipal) rationing prosecutions can note that cross-MSJ is now on file with a December 15, 2026 motion date; it cannot treat the filing as a holding. Official SMF (Doc. 91-2): https://assets.nationbuilder.com/firearmspolicycoalition/pages/8901/attachments/original/1789419258/2026.09.14_091-2_SMF.pdf. Tracker: https://www.firearmspolicy.org/struck. CourtListener: https://www.courtlistener.com/docket/69201905/struck-v-platkin/. New (official Doc. 91-1 TOA + introduction, captured Buzz 280 / 2026-09-17). The Sept. 14 MSJ cites Wolford v. Lopez, 146 S. Ct. 2032 (2026); United States v. Hemani, 146 S. Ct. 1677 (2026); and Ass'n of N.J. Rifle & Pistol Clubs v. Att'y Gen. N.J., 183 F.4th 211 (3d Cir. 2026) (Cheeseman/ANJRPC en banc, HI #59) passim, plus Nguyen v. Bonta, 140 F.4th 1237 (9th Cir. 2025). Intro (Doc. 91-1 at 2) quotes Nguyen: one-gun-a-month laws are 'facially unconstitutional because possession of multiple firearms and the ability to acquire firearms through purchase without meaningful constraints are protected' (140 F.4th at 1239–40). Quote Nguyen (and Cheeseman if in the Third Circuit), not this pending motion, in a CA paper. Lift the prior 'Doc. 91-1 image-scan / do not harvest' fence as to the TOA and introduction; remaining body pages are still a scan. Official memo: https://assets.nationbuilder.com/firearmspolicycoalition/pages/8901/attachments/original/1789419257/2026.09.14_091-1_Memo_ISO_P's_%28FPC%29_MSJ.pdf. Still not a holding. 2C:58-3(i) remains in force.

Cert petition filed Sept. 16, 2026 — not yet assigned a public merits docket number as of 2026-09-17 (SCOTUS public HTML checked through 26-360; last docketed that day is unrelated). 26A142 remains the extension only (docketed July 30, 2026; Justice Sotomayor granted to Sept. 16, 2026). Counsel of record David H. Thompson, Cooper & Kirk; Nicolas J. Rotsko, Fluet. Petitioners: Brett Christian, Firearms Policy Coalition, Second Amendment Foundation. Respondents: Steven G. James (NYSP Superintendent) and Michael J. Keane (Erie County DA). Lower: 2d Cir. Nos. 24-2847 & 25-384, Christian v. James, 176 F.4th 189 (May 18, 2026) — affirmed the private-property-open-to-the-public win and UPHELD New York's undifferentiated public-parks ban. District: W.D.N.Y. 22-CV-695 (JLS), 2025 WL 50413 (Jan. 8, 2025). Statute at issue: N.Y. Penal Law § 265.01-e(2)(d) (public parks; privately held land inside a park/forest preserve excluded). Not a grant. Not a merits holding of this Court. § 265.01-e remains in force. Distinct from Novotny v. Moore (HI #27) (MD location bans, already distributed for the Sept. 28 conference) and May/Carralero (HI #52) (CA SB 2) — do not merge.

Portable parks / sensitive-places + analogue-era vehicle, not a New York charge win and not a grant. Direct for NY PDs on § 265.01-e(2)(d) park/forest files. For California: pair with May/Carralero (HI #52) (SB 2 location bans, stay lifted) and Novotny (HI #27) (MD location-ban cert already at conference). Harvest the three QPs and the 2d Cir. move of treating 'urban parks' history as enough for a statewide parks ban — that is the government's likely Bruen-step-two / facial line in CA park and SB 2 papers. Do not cite the petition as invalidating any park ban. Continuance/stay language in park-location prosecutions can note that a cert petition on this exact question is on file (SAF/Cooper & Kirk PDF dated Sept. 16, 2026); it cannot treat filing as a grant. Official petition: https://saf.org/wp-content/uploads/2026/09/Christian-cert-petition_9.16.26.pdf. Extension docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26A142.html.

Cert-stage, petition not yet filed — 9th Cir. No. 24-5536. Panel opinion filed Jan. 30, 2026, published as Knife Rights, Inc. v. Bonta, 165 F.4th 1330 (9th Cir. 2026) (Wardlaw, J., joined by Gould and Koh): AFFIRMED S.D. Cal. summary judgment for the State on different grounds. Official panel PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/01/30/24-5536.pdf. En banc denied July 16, 2026 (Wardlaw/Gould/Koh concurrence; VanDyke dissent; Tung dissent joined by Callahan, R. Nelson, Collins, Lee, Bress, Bumatay, and VanDyke). Official en banc-denial PDF: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/07/16/24-5536.pdf. District: S.D. Cal. 3:23-cv-00474-JES-DDL (Simmons, J.). NEW (official SCOTUS docket 26A352, docketed Sept. 15, 2026): Application submitted Sept. 11, 2026 to Justice Kagan to extend the time to file a petition for a writ of certiorari from October 14, 2026 to December 13, 2026. Counsel of record David H. Thompson, Cooper & Kirk. Official application PDF: https://www.supremecourt.gov/DocketPDF/26/26A352/423955/20260911150626395_knife%20rights%20-%20extension%20petition%20vpf1.pdf. Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26A352.html. Not a petition. Not an extension grant. Not a cert grant. Cal. Penal Code §§ 21510, 17235, 21590, 18000, and 18005 remain in force. Distinct from PWGG v. Bonta (HI #41) (same retailer plaintiff; under-21 acquisition, different docket) — do not merge.

Direct California utility tomorrow morning on Penal Code § 21510 (and related §§ 17235 / 21590 / 18000 / 18005) switchblade files. Do not cite Knife Rights as a win: the Ninth Circuit is adverse on the facial challenge, en banc was denied, no petition is on file, and the Kagan application is only a request to move the cert deadline from Oct. 14 to Dec. 13, 2026 — not granted on this pass. Immediate uses: (1) continuance/stay hook in § 21510 prosecutions while 26A352 is pending and until a petition is filed or denied; (2) the panel's own fence — it decided only the concealed-carry application and left open whether other applications (open carry, mere possession, sale) are constitutional, which is the as-applied opening the Tung dissent flags; (3) do not tell a court that Rahimi/Salerno 'one valid application kills the facial challenge' is the last word on a total carry ban — quote the filed panel opinion and the Tung dissent if used at all, not X. Distinct from PWGG v. Bonta (HI #41): PWGG, LP is a named plaintiff here, but HI #41 is the under-21 acquisition vehicle. Official docket: https://www.supremecourt.gov/docket/docketfiles/html/public/26A352.html. Panel: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/01/30/24-5536.pdf.

Open — D. Md. 1:26-cv-02074-RDB (Bennett, J.) (consolidated). Complaint filed May 26, 2026 (day of bill signing). Amended complaint June 25; PI motions ECF 21 (July 20) and ECF 29. Defendants' consolidated opposition to PI filed August 14, 2026. NEW (letter order signed and entered Sept. 14, 2026): hearing on Plaintiffs' Motions for Preliminary Injunction (ECF Nos. 21, 29) set for Friday, September 25, 2026, 11:00 a.m., Courtroom 5D, 101 W. Lombard Street, Baltimore (Northern Division). Not a ruling. SB 334 (machine-gun-convertible / Glock-style pistol ban) remains in force; effective January 1, 2027. Distinct from The Firing Pin v. James (HI #60) and United States v. California (HI #78) — do not merge.

High-value authority for challenges to convertible-pistol / “Glock ban” statutes (parallels NY Firing Pin v. James). Supplies common-use, text-and-history, and “already-illegal conversion” framing usable in acquisition, sales, and possession cases. Useful for California counsel watching similar feature-based or conversion-based restrictions. Bank-signal candidate for convertible-pistol / common-handgun module. NEW (letter order Sept. 14, 2026): PI hearing calendared Friday, September 25, 2026, 11:00 a.m., Courtroom 5D (Bennett, J.). Not a ruling. Do not tell a California court that Maryland's Glock ban is enjoined. Use the date only as a watch item for a forthcoming written PI order that could supply common-use / already-illegal-conversion language for CA AB 1127 / PC 27595 papers. Quote a written order, not the letter that set the hearing.

Open — 5th Cir. No. 24-50564. Official published order Sept. 14, 2026: majority of active judges voted for rehearing en banc with oral argument to be set; Clerk to set supplemental-brief schedule; panel opinion dated May 20, 2026 VACATED (5th Cir. R. 41.3). Official PDF https://www.ca5.uscourts.gov/opinions/pub/24/24-50564-CR1.pdf. No dissent on the grant order. Panel (Haynes, Ho, Oldham) had AFFIRMED W.D. Tex. 7:24-CR-31-1. Predicates: Texas drug possession in a drug-free zone and evading arrest/detention with a motor vehicle (state-jail felony, Tex. Pen. Code § 38.04(b)(1)(B)). Defendant was not sentenced to prison on the predicates; probation had ended ~seven years before the § 922(g)(1) possession. Not a holding that § 922(g)(1) is invalid. Statute remains in force. Distinct from Squire (HI #82/#43) (same circuit, Commerce Clause / Scarborough en banc) — do not merge. Distinct from Hembree (HI #38) (simple drug possession; SCOTUS 25-1219).

Federal and Fifth Circuit 922(g) calendars: live en banc vehicle on the no-prison-time / stale-predicate / Diaz-critique line. Use for continuances and as-applied briefing while the case is pending; do not tell a client the ban is enjoined. Ninth Circuit still treats 922(g)(1) as facially valid. California state felon-in-possession analogues remain in force. Portable pieces: (1) punishable-by-more-than-a-year is not the same as served-time; (2) Ho/Oldham language on lifetime bans after completed probation; (3) keep Squire (Commerce) and Cordova (as-applied 2A) on separate tracks.

Open — petition for certification pending at the New Jersey Supreme Court (not granted). Lower: N.J. Super. App. Div. A-3192-24 (Gummer, Paganelli, Vanek), unpublished per curiam June 18, 2026, official PDF https://www.njcourts.gov/system/files/court-opinions/2026/a3192-24.pdf, affirming Warren County Law Division GPA-0006-24 (May 22, 2025) that upheld the NJSP April 11, 2024 FPIC denial. App. Div. affirmed on a mixed totality under N.J.S.A. 2C:58-3(c)(5) (prior Freehold denials, authorized 2017 psych records, a family incident, and online posts) and said there was enough even without the psych records. Constitutional attacks treated as inadequately briefed and as foreclosed by In re M.U., 475 N.J. Super. 148 (App. Div. 2023). Not precedential (R. 1:36-3). Not a speech-only holding. CONFIRMED (SAF brief filed Sept. 8, 2026; official App. Div. opinion pulled Sept. 12): SAF amicus (Schmutter / Hartman & Winnicki) urges the Court to GRANT certification and reverse, or grant the pending M.U. petition and remand. No public C-number located on this pass. Certification is sought, not granted. 2C:58-3(c)(5) remains in force. Distinct from Pratt v. Westbrook (HI #90).

Portable suitability / good-moral-character contrast for CA CCW and GBI clients when the State leans on 'character,' social-media, or uncharged speech instead of a conviction or an objective prohibitory category. Pair with Pratt v. Westbrook (HI #90) and Bruen n.9. Do not cite the June 18 opinion as a win or as 'speech-only' law: it is unpublished, the panel said the constitutional claims were poorly briefed, and the record is not speech-alone. Immediate uses: (1) motion language that licensing may use narrow objective criteria, not a temperament veto; (2) fence for prosecutors who want to import NJ (c)(5) rhetoric into a CA suitability hearing; (3) watch the NJ Supreme Court petition — a grant would raise the analogical value, a deny leaves M.U. as the NJ intermediate rule. Bank signal: queued — suitability / speech-as-disqualifier module. Do not write the bank from this seat.

Pending in U.S. District Court, E.D. Virginia (Judge Leonie M. Brinkema). No preliminary injunction ruling yet as of July 2026. Response deadlines extended to July 31, 2026. Filed May 2026.

Clean federal 2A / Bruen framework challenge that complements the state constitutional theories in the parallel Curtis and Crump cases. Valuable for extracting high-quality historical analysis, standing arguments, and PI/TRO briefing that can be adapted for federal 1983 actions, habeas petitions, or persuasive authority in state courts.

SCOTUS cert petition filed (No. 26-184) – pending

Strong free-speech / arms-information framing. Useful for any case involving distribution of CAD files, digital designs, or technical information about firearms manufacture. Portable language on the intersection of 1A and 2A when the state targets the speech that enables the right. Still early (cert stage); monitor for grant or summary action.

Stipulated Judgment and Permanent Injunction entered August 14, 2026 (D. Haw. 1:26-cv-00233-MWJS-WRP).

Direct enforcement tool for Hawaii PTA delay/denial cases in Kauai. Pattern evidence of Alan Beck forcing Hawaii counties to comply with state statutory processing deadlines via 2A + state-law overlay. Modest portable value for “shall-process within X days” challenges elsewhere.

Cert pending — SCOTUS No. 25-1324 (docketed May 29, 2026; linked 25A1140). Petition live. Maryland Brief in Opposition filed Aug. 17, 2026. Petitioners' reply SUBMITTED Sept. 2, 2026 (Reply of Katherine Novotny and Susannah Kipke, et al.; counsel of record David H. Thompson, Cooper & Kirk). Official docket same day: DISTRIBUTED for Conference of Sept. 28, 2026. Reply asks the Court to grant certiorari or, in the alternative, GVR in light of Wolford v. Lopez. State's vampire-rule cross-petition dismissed Aug. 13, 2026 (Rule 46). Fourth Circuit (Jan. 20, 2026; Nos. 24-1799, 24-1827, 24-1834, 24-1836) upheld most location bans while striking the private-property default. Not a grant. Maryland Gun Safety Act of 2023 location bans remain in force.

Not a holding and not a grant. The live SCOTUS ask is now on the official docket: grant, or GVR in light of Wolford. Quote the filed reply, not X. Official PDF: https://www.supremecourt.gov/DocketPDF/25/25-1324/422804/20260902141528155_25-1324%20Reply%20Brief.pdf. Reply framing portable to California sensitive-places / gun-free-zone practice: Wolford's holding that the Second Amendment protects carry 'as they go about their daily lives' (146 S. Ct. at 2041) is incompatible with a 'tight web of laws that severely restricts the carrying of firearms for self-defense'; there is nothing 'exceptional' about visiting a park or riding public transit. Historical principle offered: locational bans are traditional only where the government actually secures the place against armed attack (courthouses, legislatures, polling places) — not unsecured parks, transit, restaurants, or forests. Do not cite as invalidation of any California location ban. The Ninth Circuit's Aug. 10, 2026 Wolford remand memo said analysis of other Hawaii location restrictions is 'unaffected' (2026 WL 2291925) — that tension is the GVR hook, not a CA win. Conference is Sept. 28, 2026; watch the order list. Pair with Carralero v. Bonta (HI #52) and Koons v. Platkin (HI #64). Bank signal: queued — harvest Wolford daily-life + government-security principle into the sensitive-places module; do not mint a Maryland-only card. Data: do not write the bank from this seat.

On hold. Conference scheduled 2026-06-29 (per FPC tracker).

Direct California authority for LCM / magazine-capacity challenges. Strong portable framing for other states’ magazine bans and for “common use” / historical-tradition arguments in acquisition and possession cases.

On hold. Conference scheduled 2026-06-29 (per FPC tracker).

Parallel magazine-ban authority useful for California defenders facing LCM charges or civil restrictions; reinforces “common use” and historical-tradition arguments that travel across jurisdictions.

On hold. Conference scheduled 2026-06-29 (per FPC tracker).

AWB framing at SCOTUS level; useful for California assault-weapon / feature-based ban challenges and for distinguishing “common use” versus “dangerous and unusual” arguments.

Distributed for Conference on 2026-09-28 (per FPC tracker).

Another live 922(g)/status-based vehicle at the Court. Useful for monitoring government posture and for building as-applied or facial arguments in California federal and state prosecutions involving prohibited-person status.

Open — Cross-SJ oral argument held Aug 24, 2026 at 10:30 a.m. before Judge John L. Kane (D. Colo.); taken under advisement; written decision pending. PI denied Nov. 13, 2023. Cross-SJ briefed May–July 2025. Key 10th Cir. authority Ortega v. Grisham (HI #77) is now a plaintiff-only final judgment on remand (D.N.M. Docs 126–127, Aug. 27, 2026), not merely a PI reversal. Colorado's 3-day wait remains in effect until Kane rules.

High-value vehicle for waiting-period / cooling-off / post-background-check delay arguments. Direct 10th Cir. authority is Ortega (HI #77): acquisition is protected; categorical waits lack historical analogue. As of Aug. 27, 2026 that holding is a final judgment on remand — still plaintiff-only in New Mexico, but binding circuit law in Colorado. Use Ortega's mandate/law-of-the-case language if a trial court tries to treat the published reversal as 'only a PI.' Do not overclaim: Browning did not wipe NM's statute statewide, and Kane has not yet applied Ortega to C.R.S. § 18-12-115. Pair with Beckwith (HI #39) for the 1st Cir. split and with CA 10-day (PC 26815/27540) as portable framing.

Open — C.D. Cal. (Ramírez Almadani, J.), 8:26-cv-01697-MRA-ADS. Complaint filed July 1, 2026. TRO denied July 9, 2026 (ECF 26). State PI opposition ECF 43 and DOJ opposition to MTD ECF 42 filed Aug 25, 2026. United States reply in support of PI filed Sept 1, 2026 (ECF 44) (Arrington, Acting Chief, Second Amendment Section; 4,513 words). Dual hearings Sept 11, 2026, Ctrm 9B: prior lock MTD 10:00 a.m. / PI 1:30 p.m.; ECF 44 caption lists the PI hearing at 10:00 a.m. — confirm on the minute order before calendaring. Not a holding. Glock Ban (PC § 27595(a)) and UHA CLI/MDM roster condition (PC § 32015) remain in force.

Highest immediate CA acquisition utility after Renna. For any client charged in connection with a Glock-platform pistol, unrostered handgun, AB 1127 / PC § 27595, or UHA CLI/MDM roster condition: (1) quote Heller 554 U.S. at 629 against ‘you can buy something else’; ECF 44 repeats that line and pairs it with Renna 667 F. Supp. 3d at 1062 and Boland 662 F. Supp. 3d at 1085–86; (2) lock step one to Wolford’s three inquiries — oppose any extra ‘meaningful restraint’ screen the State is inviting; (3) acquisition is keep: Nguyen (9th Cir.) + Ortega (10th Cir.) + Ezell, now collected in one federal PI reply on this docket; (4) MDM can disable the gun without a magazine — Boland language reused here for self-defense burden; (5) § 12601 is a federal-enforcement overlay, not a private cause of action, but ECF 44’s concession-and-pattern theory is the stall-breaker on the MTD. Flag the Sept 11 dual hearing if seeking a continuance. Do not treat Renna as the Glock-ban case after ECF 112. Pair with Boland (MDM/CLI) and Renna HI #50.

Cert pending — SCOTUS No. 26-60. Petition filed July 10, 2026 (docketed July 14). Respondents waived Aug 12, 2026; Court requested a response Aug 26, 2026 (due Sept 25, 2026). Distributed for Conference of Sept 28, 2026. Not a grant. Lower: 4th Cir. No. 24-1822 (King & Wynn; Quattlebaum, J., dissenting), Feb 11, 2026, reversed E.D. Va. Article III standing dismissal and vacated the alternative PLCAA merits dismissal as advisory. District: Hilton, J., Lowy v. Daniel Defense, 1:23-cv-01338 (consol. Harris 1:23-cv-01501), dismissed July 24, 2024.

Not a criminal-charge 2A holding and not a cert grant. Living value: (1) PLCAA / manufacturer-marketing watch — consumer-protection and false-advertising theories used to impose industry-wide liability for a third-party crime; (2) Article III independent-criminal-actor traceability, including the Quattlebaum dissent; (3) First Amendment (petition also flags Second Amendment) protection of speech promoting lawful arms. Use 167 F.4th 175 when a filing needs the standing/PLCAA overlay; pair with Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos, 605 U.S. 280 (2025). Do not cite response-requested as a grant. Distinct from Defense Distributed HI #21 (SCOTUS 26-184, 3D-printer files) and #31 (N.D. Tex. frame/receiver). Bank signal: queue PLCAA / marketing-causation / third-party-traceability only if cert is granted or the BIO/reply produces usable quotes. Do not write the bank from this seat.

Decided — 9th Cir. No. 25-693, published Aug. 27, 2026. Panel 2-1 (Koh, J., joined by de Alba, J.; Lee, J., dissenting in part) AFFIRMED C.D. Cal. (Selna, J., 8:23-cv-02413) Rule 12(b)(6) dismissal. Plaintiffs stipulated away the Second Amendment claim (June 24, 2024); the opinion is 1A/4A/5A only. Statute remains in force. En banc / cert window open. Not a holding that § 26806 is 2A-valid.

Adverse published 9th Circuit authority for California gun cases that try to suppress FFL store recordings as a government search. Majority: a search, if any, occurs when the government actually accesses the recordings — not when the dealer’s cameras roll. Do not rest suppression on a ‘moment of recording’ theory, or on the dealer being a state actor merely by complying with § 26806. If DOJ/ATF/local actually obtained the files (warrant, court order, or inspection), that acquisition is the 4A event; Carpenter and Chatrie still apply to government access. Lee dissent is usable for home-FFL inspection (unbridled timing, including hypothetical 2 a.m. / Christmas-Day searches) and for 1A chill of political talk at gun shops, but it is a dissent. Distinct from Richards v. Bonta (HI #51), the CA 10-day waiting-period case — do not merge the rows.

Open — 5th Cir. No. 25-30324, rehearing en banc granted (United States v. Squire, 182 F.4th 481 (5th Cir. 2026); Higginson, J., dissenting from the grant). From E.D. La. (Vitter, J.), cover docket 2:24-CV-41-1. Louisiana amicus (Murrill / Aguiñaga) filed in support of appellant and reversal: do not facially invalidate § 922(g)(1); construe 'possess in or affecting commerce' to require a present connection to ongoing interstate commerce. NEW (Sept. 10, 2026): FPC amicus urging the en banc court to hold that Congress cannot use the Commerce Clause to turn purely local firearm possession into a federal crime merely because the gun crossed a state line in the past (Lopez / Morrison; noneconomic local conduct). FPC points to Thomas, J., in Hemani, 146 S. Ct. 1677, 1696 (2026) (§ 922(g)(3) Commerce Clause critique; cited FPC's Hemani amicus). Amicus, not a holding. Ninth Circuit remains Scarborough-bound. Statute remains in force.

Federal 922(g)(1) preservation and element-challenge tool, not a California dismissal case. Ninth Circuit still treats Scarborough as requiring only that the firearm previously traveled in interstate commerce. Do not cite Squire as binding in C.D. Cal. / 9th Cir. Use for: (1) preserving a present-connection / as-applied Commerce Clause argument in CA federal FIP cases while 5th Cir. en banc is pending; (2) distinguishing 'receive ... which has been shipped or transported' from 'possess in or affecting commerce' (Louisiana's surplusage argument); (3) continuance/stay language if the en banc opinion creates a circuit split heading to SCOTUS. Do not tell clients 922(g)(1) is void. Do not transplant into state PC 29800 analogue cases — those are not Commerce Clause statutes. Distinct from Rahimi/Bruen dangerousness (status) and from HI #25 (925(c) restoration), #37 Harris, and #38 Hembree.

Decided — 3d Cir. No. 24-2125, published Sept. 1, 2026 (Restrepo, Bibas, Chung). Opinion by Bibas, J. AFFIRMED E.D. Pa. 5:22-cr-00033-002 (Leeson, J.) convictions for possessing a machinegun (18 U.S.C. § 922(o)) and an unregistered silencer (26 U.S.C. § 5861(d)). Argued July 8, 2025; held pending ANJRPC en banc. Judge Chung joins the judgment but does not join Part III (silencer non-infringement theory). Not Ninth Circuit law. Federal machinegun ban and NFA silencer registration remain in force.

Three uses for a California PD, none of them 'cite Berger and win.' First, § 922(o) / conversion-parts / machinegun cases: do not fight step one. Quote: 'At step one, machine guns are firearms, so they are “Arms” protected by the text of the Second Amendment.' Fight the transplant. Berger's war-weapon / Tommy-gun / 'not commonly used for lawful purposes' language is the sentence prosecutors will paste onto CA AWB and AR-15 charges. Distinguish the charged item: a converted automatic is not an AR-15 in common use; Viramontes/Grant (HI #1) is the SCOTUS vehicle for that rifle. Second, NFA silencer / Form 4 / 5861(d) cases: prosecutors will paste 'minimal, objective hoop' and Bruen n.9. Counter with Chung's refusal to join Part III (tension with Bruen's rejection of means-end burden balancing) and with Jensen (HI #20), which enjoined NFA registration after the tax zero-out on enumerated-powers grounds — a different theory, still operational for covered parties. Third, CA DROS / 10-day wait / CCW delay: do not let the government analogize Berger's silencer paperwork to a 10-day deprivation or a discretionary CCW delay. Bruen n.9 itself flags lengthy wait times and exorbitant fees as the as-applied out; Lawson (HI #81) is the delay vehicle. Not binding in the Ninth Circuit. Do not cite as if it binds a California court.

Open — E.D. Ky. No. 2:26-cv-00091-SCM (Meredith, J., Northern Division, Covington). FPC-supported facial challenge to the National Firearms Act. Complaint Feb. 26, 2026; amended complaint Apr. 26, 2026; cross-motions for summary judgment fully briefed (plaintiffs' MSJ Dkt. 17, Apr. 24; government cross/opposition Dkt. 21). Order signed Aug. 31, 2026: oral argument on the pending SJ motions SET for Oct. 20, 2026 at 1:30 p.m. at the United States Courthouse in Lexington, Kentucky. Not a holding. NFA remains in force. Distinct from Jensen (HI #20) (N.D. Tex. enumerated-powers injunction after tax zero-out, already operational for covered parties).

Calendar flag, not a cite. Oct. 20, 2026 argument is a continuance/stay hook only if the charged conduct is NFA registration, Form 4/Form 1, suppressor, or SBR — and only as 'the constitutional status of the NFA scheme is being briefed to judgment,' not as law. If the client is a Jensen (HI #20) covered party, that permanent injunction is the live shield; Roberts is the competing 2A + enumerated-powers merits vehicle in a different district. After Berger (3d Cir. Sept. 1, 2026) treated silencer registration as a Bruen n.9 shall-issue hoop, a written SJ ruling in Roberts — win or loss — becomes the contrast cite. California PDs: federal 5861(d) sentencings and any state analogue; this is not a California case and does not disturb PC 33410/suppressor or SBR charging today. Do not quote FPC press as a holding.

District final judgment — D. Haw. 1:24-cv-00496-JAO-WRP (Otake, J.). ECF 107 filed Aug. 31, 2026: DENIED plaintiffs' MSJ (ECF 65) and GRANTED the State's counter-MSJ (ECF 71); clerk directed to enter judgment for defendant and close. Filed Nov. 20, 2024 as Pinales v. Lopez; remaining plaintiffs Juda Roache, Aloha Strategics LLC, JGB Arms LLC, and SAF (Elijah Pinales dismissed, ECF 98). PI denied Feb. 7, 2025 (ECF 45). HRS §§ 134-2 / 134-7 remain in force. Appeal window open; Ninth Circuit next. Not a SCOTUS vehicle. Distinct from live CA 9th Cir. PWGG v. Bonta (HI #41) and IL Meyer v. Raoul (HI #63).

Do not cite as California or Ninth Circuit law. This is a D. Haw. loss. The usable piece is the intrafamilial-gift split: the court conceded no Founding-era restriction on parents gifting arms to 18–20-year-olds (militia laws cut the other way) and then used 19th-century analogues. That Founding-vs-later-history move is the Bruen-step-two hook in CA under-21 acquisition motions (PWGG #41), gift/loan/constructive-possession age arguments, and any reply to a state that analogizes only to commercial sales bans. Pair with Worth v. Jacobson (8th Cir. under-21 carry win; cert denied Apr. 21, 2025, No. 24-782) and Meyer (#63). Watch the 9th Cir. appeal — a published circuit opinion would bind CA. Hawaii law is still in force.

Open — W.D. La. 6:26-cv-02650-DCJ-DJA (Joseph, J., Lafayette). Filed July 22, 2026 as Pool v. Hodges; defendant substituted to Col. Frank J. Besson (Rule 25(d)). FAC Doc. 17 filed Aug. 27, 2026. Plaintiffs' motion for preliminary injunction (Doc. 18 / 18-1) filed Sept. 1, 2026. Prior ECF 13 (Aug. 21, 2026) limited the inquiry to La. R.S. § 40:1379.3(C)(4) and did not decide the GFSZA. Not a holding. Louisiana 21+ permit floor remains in force. Distinct from Roache v. Lopez (HI #87) (D. Haw. acquisition loss) and PWGG v. Bonta (HI #41) (CA acquisition).

Do not cite as California or Ninth Circuit law. This is a pending W.D. La. PI motion, not a holding. The usable piece for a CA defender is the permit-age / school-zone trap: a client who is 18–20 may lawfully possess but cannot get a CCW (Penal Code §§ 26150(a)(2), 26155 — 21+), and without a license the federal Gun-Free School Zones Act is a 1,000-foot felony exposure on ordinary travel. Same structure as Louisiana. Pair with Reese v. BATFE, 127 F.4th 583 (5th Cir. 2025) (18–20 are 'the people'; federal 18–20 handgun-sale ban invalid) and Worth v. Jacobson, 108 F.4th 677 (8th Cir. 2024) (21+ carry-license floor invalid). Distinguish Roache (HI #87) (adverse D. Haw. acquisition/gift judgment). CA acquisition vehicle remains PWGG (HI #41). Watch the PI — a 5th Cir. district injunction would be persuasive, not binding, in CA.

Open — D. Colo. 1:26-cv-03690-DDD (Domenico, C.J.; Starnella, M.J.). Verified complaint filed Aug. 12, 2026 (Doc. 1) by Greg Howeth, Zackary Dougherty, and the National Rifle Association. Originally assigned to Mag. Starnella; incomplete caption so no summons issued Aug. 13 (Doc. 3). Denver counsel appeared Aug. 18 (Doc. 4) and Aug. 24 (Doc. 8). Non-consent to magistrate Aug. 27 (Doc. 9); reassigned to Chief Judge Daniel D. Domenico Aug. 27/28 (Doc. 10); designation 26-cv-03690-DDD. Scheduling/planning conference set Nov. 18, 2026. CSSA announced joinder on X Sept. 1, 2026 (CSSA1926/2094839234536632693) as its '5th active lawsuit'; CSSA is not a plaintiff on Doc. 1 and is not on the CourtListener docket as of last update Aug. 31, 2026 — announced pending docket, not a party of record. Not a holding. Denver open-carry ban (D.R.M.C. § 38-117(a), (b), (f)) and Colorado resident-only CHP / limited reciprocity (C.R.S. §§ 18-12-203, 18-12-213) remain in force. Distinct from Elliott v. Denver 1:26-cv-02948 (CSSA is a plaintiff there) and the DOJ Denver AWB/mag suit — do not merge. Distinct from Johnson (HI #84) and Elite Precision (HI #83).

Do not cite as a holding — this is a pending D. Colo. complaint, not California or Tenth Circuit law. The usable piece for a CA defender is the stacked-statute / visitor-zero-carry theory: when a city bans open carry and the state will not issue or honor a nonresident CHP, a qualified visitor has no lawful public-carry channel. California analogue is the combination of PC 25400/25850 (no unlicensed public carry; open carry effectively closed) plus Hoffman v. Bonta (HI #56) (CA nonresident CCW). Immediate uses: (1) framing for a traveling client arrested in Denver or a CA client carrying on an out-of-state permit where reciprocity is closed; (2) continuance/watch hook while Howeth is live if the charge is Denver open-carry or CO nonresident CHP; (3) Wolford same-meaning-everywhere language already in the complaint (still Bruen/Rahimi merits, not Obergefell recognition). Do not clone the Motion Bank 'Obergefell for Guns' nationwide-uniformity block — that module already exists; Howeth is a city-level stacked-ban vehicle, not a twin. Distinct from Johnson (HI #84) (SCOTUS 26-255 traveler-exception / GCA-style reciprocity petition — different take) and Elite Precision (HI #83) (interstate FFL handgun sale). CSSA X (Sept. 1) is secondary; SoT is Doc. 1 + CL docket 74643179.

Open — Mass. SJC No. SJC-13822. Appeal from a Hampden County Superior Court judgment reversing a Holyoke District Court order that the LTC issue. SJC took the case directly. Oral argument scheduled Oct. 7, 2026 (GOAL). SJC called for amicus briefing. SAF/CRPA/SALC/MGOC/CCRKBA amicus dated Aug. 31, 2026 (SAF PDF 9.1.26). Not a holding. G.L. c. 140, §§ 131(d) and 121F(k) remain in force. Distinct from Lawson v. Campbell (HI #81) (D. Mass. nonresident delay MTD — do not merge).

Portable for California CCW residual-suitability / 'good moral character' fights and for clients who are not 18 U.S.C. § 922(g)(9) prohibited because there is no qualifying misdemeanor conviction. Do not cite as invalidating G.L. c. 140, § 131(d) — the SJC has not ruled; a Holyoke District Court issuance order was reversed in Superior Court. Immediate uses: (1) Bruen n.9 — shall-issue regimes may use 'narrow, objective, and definite standards,' not 'appraisal of facts, the exercise of judgment, and the formation of an opinion'; (2) Rahimi/Hemani — non-conviction disarmament must be temporary and tied to current dangerousness, not an indefinite LTC/CCW denial on decade-old unproven allegations while the person may still possess firearms; (3) Wardell — a Massachusetts CWOF / admitted-sufficient-facts disposition is not a conviction. CRPA is an amicus, so the brief is CA-org-backed. Pair with CRPA v. LASD (HI #28). Distinct from Lawson (HI #81) (processing delays, not suitability). Counsel of record for Westbrook: William Smith (GOAL); amicus local counsel Jason A. Guida.

Open — C.D. Cal. 8:22-cv-01421 (filed Aug. 1, 2022; originally Carney, J.; reassigned to Ramírez Almadani, J., after Carney retired). PI granted March 2023, published as Boland v. Bonta, 662 F. Supp. 3d 1077 (C.D. Cal. 2023): UHA microstamping, chamber-load-indicator, and magazine-disconnect requirements likely violate the Second Amendment. Ninth Circuit No. 23-55276 partially stayed the PI (CLI and MDM reinstated pending appeal; microstamping injunction remains in force). Oral argument Aug. 2023; held pending Duncan en banc; after Duncan (March 2025) supplemental briefing completed; fully briefed and awaiting the same 11-judge en banc panel as Renna (9th Cir. 23-55367). NEW (administrative, not a holding): on Sept. 3, 2026, CA DOJ added 25 semiautomatic handgun models to the Roster of Certified Handguns pursuant to the unstayed microstamping injunction (20 Smith & Wesson, 3 SIG Sauer, 2 Biofire). Official list: https://oag.ca.gov/firearms/certified-handguns/recently-added. Case still seeks complete invalidation of the UHA roster conditions. CLI, MDM, and the roster itself remain in force except as to microstamping. Distinct from Renna v. Bonta (HI #50) (S.D. Cal. 3:20-cv-02190 / 23-55367) and from United States v. California (HI #78) — do not merge.

California-primary acquisition / UHA tool, not a 'roster is dead' card. For any client charged under PC § 32000 (manufacture/sale of an 'unsafe' handgun), off-roster possession/transfer practice, or a dealer DROS issue: (1) check the official recently-added list before treating a 2026 Smith & Wesson, SIG, or Biofire model as off-roster — 25 models were certified Sept. 3, 2026 because of the unstayed microstamping PI; (2) quote Carney: the UHA conditions 'generally prohibit Californians from acquiring state-of-the-art handguns' that are protected arms, and the State identified no historical tradition (662 F. Supp. 3d at 1085–86) — that language is already reused in US v. California ECF 44 (HI #78); (3) do not tell a client the roster, CLI, or MDM is enjoined — the Ninth Circuit reinstated CLI/MDM; only microstamping stays down; (4) do not cite Renna (HI #50) as this docket, or this docket as the Glock-platform / AB 1127 vehicle (that is HI #78). Pair with Renna for the companion UHA appeal (23-55367, same en banc panel) and with HI #78 for CLI/MDM as a current enforcement target. Continuance/color: the operative PI is why new models exist on the roster at all; if Boland were dropped the freeze could return.

Open — 3d Cir. No. 25-2546 (Porter, Matey, Ambro), opinion filed Sept. 8, 2026. Official slip: https://www2.ca3.uscourts.gov/opinarch/252546p.pdf. Unanimous panel REVERSED D.N.J. Younger abstention/stay and held NSSF has associational Article III standing to challenge N.J. A1765 (N.J.S.A. 2C:58-33 to -35 public-nuisance / 'reasonable controls') after six State enforcement actions, including against members Glock and Sig Sauer. Younger does not apply: NSSF is not a party to the state suits and is not Glock's owner/manager. Catch-22 rejected — the State may not bounce the association for suing too early (NSSF I, 80 F.4th 215 (3d Cir. 2023)) and too late (Younger). Remanded for the district court to decide the preliminary-injunction request on the merits. Not a holding that A1765 is preempted by the PLCAA. Not a merits injunction. A1765 and pending State enforcement suits remain in force. District: D.N.J. 3:22-cv-06646-ZNQ-TJB (Quraishi, J.), originally NSSF v. Platkin. Distinct from Cheeseman / ANJRPC v. Davenport (HI AWB/LCM en banc) — do not merge.

Thin for a street-level CA firearms prosecution; stronger for FFL / manufacturer / association clients and for any CA case where the State or a city leans on AB 1594-style public-nuisance or 'reasonable controls' theories. Immediate uses: (1) the Porter Catch-22 paragraph when a government tries to bounce an associational challenge as both too early and too late; (2) Younger fence — membership in a trade group facing a parallel state enforcement action does not automatically wipe the federal case; (3) flag for Data as an industry-liability / PLCAA module, not as a 2A merits block. Do not tell a court A1765 has been struck. Bank signal: queued — PLCAA / public-nuisance industry module. Do not write the bank from this seat.

Decided — D. Del. 1:21-cv-01523-MN (Noreika, J.). Memorandum + order + judgment Sept. 10, 2026 (ECF 81–83). Permanent injunction on Possession Ban (11 Del. C. §§ 1459A(b), 1463(a)) and Manufacturing/Assembly Ban (§ 1463(b)–(c)). Instructions Ban (§ 1463(c)(2)) survives — First Amendment claim fails under Defense Distributed v. Att'y Gen. of N.J., 167 F.4th 65 (3d Cir. 2026). Distribution ban survives Bruen step one as commercial-sales regulation. Case closed at district; appeal window open. Distinct from Defense Distributed / SAF v. Blanche (federal frame-receiver rule; Motion Bank 215–216) and from Viramontes/Grant (HI #1, AWB merits) — do not merge. California PMF / serialization statutes (PC 29180 et seq., AB 1621 overlay) remain in force.

Persuasive only — Third Circuit district court, not Ninth Circuit law. Use the opinion's language that serialization does not define an Arm, that self-manufacture is a means of acquisition, and that operability includes disassembly, cleaning, repair, and reassembly. Cite in CA PMF / unfinished-frame / 'ghost gun' calendars (PC 29180 et seq.) as framing, not as an injunction. Do not advise that California possession or making bans are dead. Do not treat the instructions-ban loss as a green light for CAD/file-distribution theories. Pair with Motion Bank 215–216 (DD/Blanche) rather than duplicating that federal-rule card.

PI granted in part — D. Md. 8:26-cv-02963-DKC (Chasanow, J.). Memorandum Opinion ECF 35 and Order ECF 36 filed Sept. 10, 2026. Preliminary injunction (plaintiffs only) bars Montgomery County, Marc Elrich, and Marc R. Yamada from enforcing County Code §§ 57-1 and 57-11(a)(1) against Silver Spring Jewish Center, Inc. and Rabbi J. Menashe Shapiro to the extent those provisions prohibit selling, transferring, possessing, or transporting a handgun in THEIR respective places of worship. Bond waived. Facial and as-applied challenges to 100-yard buffers around other places of public assembly DENIED at the PI stage. Not a countywide injunction. Not a merits judgment. Coordinated but not consolidated with Barreto v. Montgomery Cnty., 8:26-cv-02912-DKC. State's Attorney has deferred criminal prosecutions pending resolution; County police may still issue civil citations except as to these plaintiffs. County Code Ch. 57 remains in force for everyone else. Distinct from Novotny v. Moore (HI #27) (statewide MD location-ban cert) and Carralero/May v. Bonta (HI #52) (CA SB 2) — do not merge.

Portable houses-of-worship / SB 2 location-ban authority for California clients charged in or near a church, synagogue, or mosque (PC 26230 / SB 2). Quote the order, not X: as-applied relief is limited to these two plaintiffs, and only as to a handgun in THEIR places of worship. Cite Wolford's 9th Cir. church-carry history (no colony/state/territory banned firearms at worship until after the Fourteenth Amendment), which this court treated as persuasive. Do not tell a CA court that Montgomery County's ordinance is enjoined countywide, that the 100-yard buffer is dead, or that SB 2 is invalid. Pair with Carralero/May (HI #52) as the live CA vehicle and Novotny (HI #27) as the MD statewide cert vehicle. Motion Bank already has Case Watch 207 on the July 30 filing; this is the PI, not a twin module. Official opinion: https://storage.courtlistener.com/recap/gov.uscourts.mdd.609948/gov.uscourts.mdd.609948.35.0.pdf. Official order: https://storage.courtlistener.com/recap/gov.uscourts.mdd.609948/gov.uscourts.mdd.609948.36.0.pdf.

Open — S.D.N.Y. 1:26-cv-07956, complaint filed Sept. 11, 2026 (Doc. 1, 41 pages + 10 exhibits). Civil cover sheet and summons request same day (Docs. 2–3). Judge unassigned on the first three entries. Counsel: Mirel Fisch, Law Office of Mirel Fisch. Putative Rule 23(b)(2) class of out-of-state holders of NYC Non-Resident Carry licenses subject to 38 RCNY § 5-25(g)(3)(a). Named plaintiffs: Brad G. Hendrick (Hudson Cty., N.J.), Christopher Amalfitano and Erin K. Amalfitano (Somerset Cty., N.J.), Richard M. Rocca (Northampton Cty., Pa.), Roger Restaino (Fairfield Cty., Conn.). Several have written add-firearm denials from License Division (Hendrick Jan. 23, 2025; C. Amalfitano May 13, 2026; E. Amalfitano June 8, 2026; Restaino Sept. 1, 2026). Claims: Second Amendment / § 1983; Privileges and Immunities (Art. IV, § 2); Equal Protection (14th). Relief: declaration, permanent injunction putting NC holders on the same listing terms as NY-resident Carry / Special Carry licensees, nominal damages, fees. Not a holding. § 5-25(g)(3)(a) remains in force. Distinct from Mills v. NYC (resident listing / one-gun-on-the-person) — do not merge. Distinct from Howeth and Johnson v. Jacobson.

NYC / SDNY and any PD whose client holds or is seeking a City NC card: the listing cap is a live licensing condition, not a completed merits win. Use for continuances and licensing-condition briefing while the case is pending; do not tell a client the cap is enjoined. Portable pieces nationwide: (1) already-licensed nonresident treated worse than resident on the same carry card; (2) Art. IV P&I + equal-protection overlay on listing privileges; (3) backup-gun / repair-gap theory when the only listed serial is unavailable. Not a California charge. Not a holding.

Live history (permanent injunction issued; later dissolution/appeal activity)

Non-resident and out-of-state applicant issues. Membership-certificate practical utility for CA public defenders handling multi-state clients.

On appeal. Three-judge panel (Gibson County Chancery) declared both statutes unconstitutional, void, and of no effect on Aug 22, 2025. Court of Appeals stayed the judgment Sept 30, 2025; statutes remain enforceable. Oral argument held June 23, 2026 (W2025-01327-COA-R3-CV). Plaintiffs filed supplemental authority citing Wolford v. Lopez (July 1, 2026). Decision pending.

Strong portable framing for any statute that treats the exercise of the right to bear arms as a crime first and a defense second. Direct authority that parks and recreational areas are not sensitive places. Useful language for attacking vague “intent” or “going armed” offenses, burden-shifting schemes, and expanding sensitive-place lists. Dual federal/state constitutional holding provides comparative value for state-constitution arguments.