Ronald Koons v. Attorney General New Jersey
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed in Part
Addressing multiple Second-Amendment challenges to New Jersey’s post-Bruen firearm statute, the Third Circuit upheld most of the State’s newly designated ‘sensitive-place’ carry bans (including parks, libraries, bars, casinos and healthcare facilities) and its four-character-reference permitting rule, but struck down the private-property default ban, the vehicle-carry ban as applied to private cars, the $300,000 liability-insurance mandate, and the $50 portion of the carry-permit fee earmarked for a victim-compensation fund. The court affirmed the district court’s injunction only as to those provisions it found unconstitutional and otherwise reversed the injunction, creating a split with the Ninth Circuit on whether States may simply rely on ownership of public property to forbid firearms there.
Circuit Split Identified
Legal Issue
Whether a State, acting solely as proprietor of publicly owned property, may ban the carry of firearms on that property without undertaking the historical-tradition analysis required by New York State Rifle & Pistol Ass’n v. Bruen.
Circuit Positions
Government ownership does NOT create an automatic ‘sensitive place’; Bruen’s historical-analogue inquiry still applies to carry restrictions on public property.
Government, as proprietor, may exclude firearms from property it owns or controls in the same way a private owner could, without the need for historical analysis.
Conflict Summary
The Third Circuit held that government-owned property is not automatically a firearm-free zone and that any carry restriction on such property must still be justified under Bruen’s history-and-tradition test. The Ninth Circuit, by contrast, has ruled that the State, ‘like any private property owner,’ may categorically bar firearms from premises it owns or operates, without performing the Bruen analysis.