Beckwith v. Frey

What the court held

Firearms dealers, a training school, and prospective buyers challenged Maine's law barring a seller from delivering a firearm until 72 hours after the sale agreement, and the district court preliminarily enjoined it. The First Circuit vacated the injunction, holding that the plaintiffs are unlikely to succeed on their facial claim because the waiting period only delays rather than denies acquisition and so does not regulate conduct covered by the Second Amendment's plain text at step one of Bruen. Analogizing the law to the "shall-issue" licensing regimes Bruen described as presumptively lawful, the court found the delay was not abusive toward Second Amendment rights and remanded for further proceedings.

Summarized from the court's opinion.

What this case is about

Maine’s 72-hour waiting period before a seller may deliver a firearm to a purchaser

GunMapUSA summary of the issue, not a quotation from the court.

Key Dates

• 2026-04-03 — Decided
• 2025-07-28 — Argued

Sources

• CourtListener — retrieved 2026-08-08