2d Circuit Upholds License Denials by N.Y. Judge

By Stephen P. Halbrook
The Volokh Conspiracy
August 24, 2025

On August 18, the Second Circuit decided Kellogg v. Nichols, a suit under 42 U.S.C. § 1983 against a New York state judge who denied applications by two individuals for firearm licenses. The court affirmed the district court’s dismissal of their individual-capacity claims as barred by absolute judicial immunity and then dismissed their official-capacity claims for injunctive and declaratory relief as lacking an Article III case-or-controversy.

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“2d Circuit Upholds License Denials by N.Y. Judge,” The Volokh Conspiracy, August 24, 2025.