On Tuesday, January 20, the Supreme Court will hear oral argument in Wolford v. Lopez, which concerns whether the Ninth Circuit erred in holding that Hawaii may prohibit the carrying of handguns by permit holders on private property open to the public unless the property owner affirmatively gives express permission. The Ninth Circuit upheld the ban under Bruen based on the existence of merely two purported historical analogues, a 1771 New Jersey law on poaching and an 1865 Louisiana Black Code law.

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