Wolford v. Lopez (Concealed Carry on Private Property Open to the Public)
Current understanding
The Supreme Court held that Hawaii’s statute barring licensed concealed-carry permit holders from carrying handguns on private property open to the public absent the property owner’s express consent violates the Second and Fourteenth Amendments. Applying the historical-analogue framework from New York State Rifle & Pistol Association v. Bruen, the Court found no sufficient historical tradition supporting a default-prohibition regime for privately owned but publicly accessible premises. The decision creates binding precedent that will constrain similar ‘vampire rule’ or default-no-carry statutes enacted in other states after Bruen.
Evidence log
- 2026-07-16 — To authorize possession of a firearm in certain units and facilities of the Federal Government, and for other purposes.: cross-connection with firearm-possession-federal-facilities: Both concern the scope of ‘sensitive places’ where firearm carry may be restricted or permitted post-Bruen — Wolford addresses private property open to the public; HR9719 addresses federal facilities. (novelty: 2)
- 2026-06-25 — Wolford v. Lopez: cross-connection with national-constitutional-carry-act: Both address the geographic scope of lawful concealed carry — Wolford limits state authority to impose default-no-carry rules on privately owned public-facing premises, while HR645 would federally preempt state-level licensing restrictions on carry. (novelty: 4)