Arms and Accoutrements
By Stephen P. Halbrook
The Volokh Conspiracy
June 15, 2026
United States v. DeBorba, decided on June 3, is the latest Ninth Circuit decision that seeks to exclude firearm parts from protection in the reference to the “arms” that the people have a right to keep and bear. The court held that “‘optional accessories’ to firearms—such as gun slings, scopes, and, importantly, silencers—fall outside of the Second Amendment’s plain text because they are ‘accoutrements’ and not arms.” The test for whether an object is included in “arms” is supposedly based on whether it “is necessary to the ordinary operation of the weapon.” “Ordinary” means anything you want it to mean.
“Arms and Accoutrements,” The Volokh Conspiracy, June 15, 2026.
