Giambalvo v. Suffolk Cnty.

What the court held

License applicants and firearms instructors brought facial Second Amendment challenges to New York's Concealed Carry Improvement Act -- the good-moral-character standard, the in-person interview and disclosure requirements including social media accounts, and the eighteen-hour training requirement -- plus Suffolk County's practice of taking far longer than 30 days to process applications and an alleged county policy of arresting people who handle firearms during the state-mandated live-fire training. The Second Circuit held the applicants did have standing, contrary to the district court, but affirmed the denial of a preliminary injunction because they were unlikely to succeed on the merits as to each licensing provision and as to the claim that any process exceeding 30 days is unconstitutional; the social media claim was moot given a separate injunction. It also held that plaintiffs had shown standing to challenge the arrest policy, vacated the denial of relief on that claim without reaching its merits, and remanded.

Summarized from the court's opinion.

What this case is about

facial Second Amendment challenge to Suffolk County's firearm licensing regime

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

Key Dates

• 2025-09-12 — Decided

Sources

• CourtListener — retrieved 2026-08-08