What did the Oregon Court of Appeals say in its March 12, 2025 opinion upholding Measure 114?
Executive summary
The Oregon Court of Appeals, in Arnold v. Kotek issued March 12, 2025, unanimously held that all provisions of voter-approved Measure 114 are facially constitutional under Article I, section 27 of the Oregon Constitution, reversing a Harney County trial judge’s earlier ruling that had kept the measure blocked for more than two years [1] [2]. The opinion concluded the permit-to-purchase program, point-of-transfer background checks and the ban on large-capacity magazines are reasonable safety regulations rather than an unlawful prohibition on possessing or using firearms [1] [3].
1. What the court said — the bottom line
The court’s 25-page opinion states plainly that “all of Measure 114 is facially constitutional” under the state constitution and lifts the legal foundation of the Harney County decision that had enjoined the law, effectively allowing Oregon to proceed toward implementing the voter-approved restrictions unless the state Supreme Court intervenes [1] [4].
2. How the court analyzed the permit-to-purchase program
On the permit requirement, the panel rejected the plaintiffs’ assertion that the program would amount to an effective ban by causing a mandatory, extended delay; instead the opinion observed the measure requires permit agents to act within 30 days and allows for earlier action when qualifications are met, making the permit regime a “reasonable” regulatory response to identified public-safety concerns rather than an absolute curtailment of the right to armed self-defense [1] [5].
3. What the court said about point-of-transfer checks and the Charleston loophole
The appeals court viewed the point-of-transfer background check and the procedural changes intended to close the “Charleston loophole” as within the state’s authority to protect public safety, citing the statutory design that combines criminal-background screening with safety training for purchasers and treating those measures as lawful exercises of regulatory power rather than per se infringements of constitutional rights [3] [6].
4. The court’s treatment of the large-capacity-magazine ban
Addressing the ban on magazines capable of holding more than ten rounds, the court disagreed with the lower court’s conclusion that the restriction impermissibly curtailed the use of “nearly any firearms,” finding instead that the limitation does not unduly frustrate the state constitutional right to armed self-defense and is a permissible regulation aimed at reducing the lethality of mass shootings [1] [5].
5. Reversal of the lower court and the legal framing
The Court of Appeals explicitly found that the Harney County judge applied an incorrect legal framework in his 2023 ruling, reversing his injunction and declaring the measure facially constitutional; courts and commentators note this follows a line of federal and state decisions that have, at various times, upheld elements of Measure 114 while the litigation proceeded through multiple forums [7] [8].
6. Reactions, political context and next procedural steps
Supporters hailed the ruling as respect for voters and a step toward implementing “common sense” safety measures, while challengers announced plans to appeal to the Oregon Supreme Court — which, as news outlets and advocacy groups report, could keep the injunction in place pending its review and thus determine whether the appeals-court decision takes effect statewide [5] [8] [4]. Reporting also situates the opinion amid wider political contention over gun policy in Oregon, including legislative attempts to tweak Measure 114 and partisan messaging that frames the decision either as vindication of voter intent or as judicial overreach depending on the source [9] [2].
7. Practical implications and unresolved questions
Although the appeals court cleared a major legal hurdle by validating the measure’s text and statutory mechanics, practical questions remain about implementation timing, administrative capacity to issue permits within statutory windows, and whether the Oregon Supreme Court will accept and potentially reverse the decision; available reporting and the court’s opinion itself do not resolve those future procedural and operational uncertainties [1] [10].