How have U.S. federal courts ruled on laws banning firearms at public assemblies since 2022?

Checked on January 31, 2026
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Executive summary

Since the Supreme Court’s 2022 Bruen decision, federal courts have repeatedly invalidated a range of laws that ban firearms at or around public assemblies—especially broad prohibitions on carrying in public-facing private property and open-carry bans—by applying Bruen’s historical-analogy test, even as some other firearm rules have survived and a fractured circuit landscape promises more Supreme Court review [1] [2] [3].

1. How Bruen reshaped the rulebook: the historical‑analogy test took center stage

In Bruen, the Supreme Court required courts to judge modern gun rules by whether they are "consistent with the Nation’s historical tradition of firearm regulation," a test that has sharply limited reliance on modern public‑safety justifications and shifted litigation toward antiquarian fact‑finding about colonial and founding‑era laws [1].

2. Immediate downstream effect: many bans on carrying in public places were struck down

Lower federal courts used Bruen to rule that broad bans on carrying guns in spaces that serve as public assembly points—such as private property open to the public and transportation hubs—violate the Second Amendment unless a historical analogue can be found, with district courts and appeals courts overturning such restrictions in multiple states since 2022 [2] [1].

3. High‑profile appellate reversals: California’s open‑carry ban and similar decisions

In late 2025 and early 2026, federal appellate panels applied Bruen to strike down California’s long‑standing bans on open carry in most populous counties and other state limits, with the 9th Circuit ruling the restrictions ran afoul of Bruen’s framework [3] [4] [5]. Those decisions illustrate how appeals courts are increasingly willing to invalidate traditional public‑assembly restrictions when they find no adequate historical analogue [3].

4. The private‑property line: Hawaii and the incoming Supreme Court argument

Challenges to bans on carrying on private property open to the public produced conflicting findings in lower courts and prompted the Supreme Court to agree to hear a case about laws banning guns on private property—reflecting dispute over whether colonial statutes about trespass or fenced lands are valid historical analogues for modern retail and assembly spaces [6].

5. Not every restriction falls: some modern rules have been upheld or left intact

The court system’s moves are not uniformly pro‑gun: the Supreme Court upheld federal rules restricting access to so‑called “ghost‑gun” kits in a 7–2 decision, and the justices declined in 2025 to take up certain challenges to assault‑weapon bans—showing the post‑Bruen picture is complex and not a blanket nullification of gun regulation [7] [8].

6. A fractured map: circuit splits, uneven outcomes, and more litigation ahead

Because judges apply Bruen’s historicism unevenly—some courts find colonial analogues that others reject—federal rulings on assembly‑related bans have produced circuit splits and conflicting district‑court outcomes, which in turn have flooded the courts with Second Amendment challenges and made Supreme Court review likely on several fronts [1] [9] [2].

7. Competing narratives and hidden incentives in reporting and litigation

Advocates for gun safety warn that Bruen’s test undermines public‑assembly protections and imperils “sensitive‑place” restrictions, while gun‑rights litigants and conservative jurists argue that longstanding prohibitions were never grounded in the Second Amendment; both sides harness courtroom victories for political pressure, and publication coverage often spotlights dramatic reversals without always explaining the arcane historical analysis that underpins them [10] [1] [2].

8. What to expect next: Supreme Court cleanups and continued uncertainty

With the Supreme Court taking cases tied to carrying on private property and other Bruen fallout, and with appellate courts continuing to invalidate assembly‑related bans in several jurisdictions, the national legal landscape will remain unsettled until the high court articulates clearer standards or narrows Bruen’s reach; until then, outcomes will depend heavily on judges’ interpretations of historical analogues and on the ideological makeup of the tribunals deciding these disputes [6] [1] [3].

Want to dive deeper?
What Supreme Court cases since Bruen have defined 'sensitive places' where guns can be barred?
How have federal appeals courts divided on bans of firearms on private property open to the public since 2022?
Which modern firearm regulations have federal courts upheld post‑Bruen, and why?