The Modern Supreme Court's Major Firearms Cases, Explained

For most of the twentieth century the Supreme Court had almost nothing to say about the Second Amendment. United States v. Miller in 1939 was the main precedent, and it was ambiguous enough that both sides cited it for decades.

That changed in 2008. What follows is a defined set of the Court’s major modern firearms cases, in order: constitutional merits decisions, important statutory firearms decisions, and the currently pending rifle-ban question. It is not a claim that every procedural or firearms-adjacent order is included.

The foundation

District of Columbia v. Heller — 554 U.S. 570, decided 26 June 2008

Dick Heller, a D.C. special police officer, was refused a certificate to register a handgun he wanted at home. The District banned handgun registration outright and required lawfully owned firearms to be kept unloaded and disassembled or trigger-locked.

The Court held the Second Amendment protects an individual right to keep and bear arms, unconnected to militia service, and struck the ban down. That single holding is the foundation of everything after it. It also left the obvious question open: the District is federal territory, so Heller said nothing about whether states were bound.

McDonald v. City of Chicago — 561 U.S. 742, decided 28 June 2010

Chicago residents challenged ordinances that banned handgun possession in practice. The city argued the Second Amendment simply did not apply to the states, and the Seventh Circuit agreed, relying on three nineteenth-century decisions.

The Court reversed, holding the right incorporated against the states through the Fourteenth Amendment. After McDonald, every state and city gun law is a potential Second Amendment case. The volume of litigation the site tracks starts here.

Caetano v. Massachusetts — 577 U.S. 411, decided 21 March 2016

Jaime Caetano carried a stun gun to protect herself from an abusive ex-boyfriend and was convicted under a Massachusetts ban. The state’s high court upheld it on the reasoning that stun guns are not the sort of weapon the Amendment covers.

The Court vacated in a brief unsigned opinion, rejecting each of the state court’s rationales. The point that matters: the Amendment is not frozen to arms in existence in 1791. A small case doing quiet work that later ones lean on.

The method changes

New York State Rifle & Pistol Association v. Bruen — 597 U.S. 1, decided 23 June 2022

Two New Yorkers were denied carry licenses for failing to show “proper cause” — a special need beyond that of the general public.

The Court struck the requirement down, and in doing so changed how every Second Amendment case is decided. Lower courts had settled into a two-step test that ended in interest balancing: how important is the government’s aim, how well does the law serve it. Bruen rejected that. If conduct falls within the Amendment’s plain text, the government must show its regulation is consistent with the nation’s historical tradition of firearm regulation.

This is why so much modern gun litigation reads like history. The fights are about analogues: whether a nineteenth-century surety statute, or a colonial gunpowder-storage rule, is close enough to justify a modern restriction.

United States v. Rahimi — 602 U.S. 680, decided 21 June 2024

Zackey Rahimi was subject to a domestic-violence restraining order containing a judicial finding that he was a credible threat, and made a facial challenge to the federal statute disarming such people.

The Court upheld the statute. It is the one post-Bruen constitutional merits decision in this guide to go against the challenger, and it is the most useful case for understanding the doctrine’s shape, because it says what Bruen does not require: a historical twin. A relevantly similar principle is enough. Someone a court has found dangerous may be temporarily disarmed — and the word temporarily is doing real work.

Anyone who read Bruen as making gun regulation impossible was corrected here.

Two wins that were not really about the Second Amendment

Garland v. Cargill — 602 U.S. 406, decided 14 June 2024

After the 2017 Las Vegas shooting, ATF reversed its longstanding position and classified bump stocks as machineguns under the National Firearms Act, requiring owners to surrender or destroy them.

The Court held a bump stock is not a machinegun as the statute defines one. This is a statutory decision, not a constitutional one — it says the agency misread the law Congress wrote, and Congress remains free to write a different one. Filed under the Second Amendment in most coverage; it belongs under administrative law.

Smith & Wesson Brands v. Estados Unidos Mexicanos — 605 U.S. 280, decided 5 June 2025

Mexico sued seven American manufacturers, arguing they aided and abetted unlawful dealer sales that armed the cartels and so fell inside the PLCAA’s predicate exception.

The Court held the complaint did not plausibly allege aiding and abetting. Awareness that some unidentified dealers sell illegally, plus a failure to police distribution, is not the same as participating in a crime. Again, statutory — about the reach of the Protection of Lawful Commerce in Arms Act.

Bondi v. VanDerStok — 604 U.S. 458, decided 26 March 2025

The Court upheld ATF’s treatment of certain partially complete frames, receivers, and readily convertible kits as firearms under the Gun Control Act. That ruling concerns commercial sale, serialization, and dealer/background-check requirements for covered kits. It did not eliminate the separate federal rules governing an individual who makes a firearm for personal use. The GunMapUSA home-build history explains that distinction in more detail.

October Term 2025 opinions

United States v. Hemani — decided 18 June 2026, No. 24-1234

The government prosecuted a Texas man under § 922(g)(3) for keeping a gun at home while using marijuana roughly every other day.

The Court held the prosecution inconsistent with the Second Amendment. The government’s historical analogues — “habitual drunkard” laws, vagrancy statutes, civil commitment, surety requirements — differed from § 922(g)(3) in why they applied, how they operated, and how severely. A direct application of the Bruen method, and an illustration that the analogue has to match in more than subject matter.

Wolford v. Lopez — decided 25 June 2026, No. 24-1046

Hawaii barred permit holders from carrying onto private property open to the public unless the owner gave express consent, reversing the common-law default that a visitor has an implied license to enter.

The Court held this violates the Second and Fourteenth Amendments. Hawaii’s proffered analogues were largely colonial-era and did not do the work. Together with Bruen, the effect is that a state cannot re-impose by default rule what it may not impose by licensing.

What is coming

Viramontes v. Cook County (No. 25-238) and Grant v. Higgins (No. 25-566) — certiorari granted 30 June 2026, consolidated, not yet argued. Higgins is the live caption.

Cook County bans AR-15-platform rifles and large-capacity magazines; Connecticut restricts semiautomatic rifles it classifies as assault weapons and limits magazine capacity. The Court’s grant is limited to the question presented in Viramontes, so this article does not describe magazine capacity as a separately accepted question. The Seventh Circuit ruled against the challengers in June 2025.

This is the question the Court repeatedly declined to take after Bruen, and the biggest unresolved issue in Second Amendment law: whether a state may ban the most popular rifle in the country. There is no decision, no argument date in these records, and anyone telling you how it will come out is guessing.

The pattern

Two decisions established the right and applied it to the states. One confirmed it is not limited to eighteenth-century technology. One changed the method by which every case is now decided. One marked the limits of that method.

Three major statutory decisions — Cargill, Smith & Wesson, and VanDerStok — sit alongside the constitutional line. The biggest open question — semiautomatic rifles — is now on the Court’s docket for the first time.

One case in our tracker is deliberately not above. Rogers v. United States reached the Court on an NFA question about what a defendant must know to be convicted of possessing an unregistered silencer, and was then dismissed as improvidently granted. A dismissal decides nothing and binds nobody, so it belongs in a docket rather than in a guide to what the Court has held. It is listed in the tracker for completeness.

We track all of these, with the full text of each opinion, in our Supreme Court case tracker.