What: Consistent with FPC’s victories against “vampire rule” laws in multiple states, the United States Supreme Court today issued a major 6-to-3 decision in Wolford v. Lopez holding that Hawaii cannot presume that peaceable carry is forbidden on private property held open to the public unless the owner first gives express permission. In the decision, the Court held that this reversal of the longstanding common-law default unconstitutionally infringes upon the exercise of the right to bear arms and violates the Second and Fourteenth Amendments.
The Court explained that these laws did not merely regulate where licensed people could carry. Instead, they severely burdened the ordinary exercise of the right to bear arms by forcing peaceable people to seek permission before entering the stores, restaurants, gas stations, pharmacies, and other businesses they visit every day. That burden, the Court held, is incompatible with the Second Amendment’s protection of the right to carry firearms for self-defense as Americans go about their daily lives.
The case against the State of Hawaii was brought by three individuals and the Hawaii Firearms Coalition. Notable amicus briefs filed in support of Wolford include those by FPC, California Gun Rights Foundation, and the United States. FPC has successfully blocked enforcement of “vampire rule” laws in multiple states, including California, Maryland, New Jersey, and New York.
Who: The Court’s opinion for Wolford was written by Justice Alito. A concurring opinion was written by Justice Barrett and partially joined by Justices Thomas and Gorsuch. Dissenting opinions were written by Justice Kagan and Justice Jackson (joined by Justice Sotomayor).
When: June 25, 2026.
Where: The United States Supreme Court in Washington, D.C.
Why: Today’s ruling confirms what FPC has argued from the beginning: States may not nullify Bruen by turning ordinary places open to the public—stores, restaurants, parking lots, and other public-facing private property—into carry-prohibited zones by default. The historical record does not support forcing peaceable people to obtain advance permission before carrying for self-defense in places held open to them. The colonial laws Hawaii relied on were anti-poaching and trespass rules, not public-carry bans, and the Reconstruction-era laws Hawaii relied upon were part of the notorious Black Codes enacted to disarm newly freed Black Americans—not evidence of the Constitution’s original meaning.
The Court rejected Hawaii’s historical analogues because they regulated unauthorized hunting—not ordinary peaceable carry for self-defense—and therefore addressed fundamentally different conduct and purposes. The Court also rejected Hawaii’s argument that the State could redefine ordinary property-law defaults to evade constitutional protections. Constitutional rights do not disappear simply because a state relabels a burden as a rule of property law.
The Court rejected the notion that Hawaii—or any other state—may carve out its own regional version of the Second Amendment. The ruling, faithfully applied, restores the ability of millions of peaceable people who live in and visit Hawaii and other states with similar laws to exercise their natural, constitutionally protected rights. These “vampire rules” were enacted after Bruen as part of a broader campaign by anti-rights states to relegate the right to bear arms to “some streets” and make lawful carry practically impossible. Today’s decision effectively resolves the central constitutional question presented by similar default-carry bans.
Quotes: “Today, the Supreme Court drove the final stake through one of the most cynical anti-rights schemes devised after Bruen. The FPC Grassroots Army has powered a string of victories against vampire rule carry bans across the country, helping build the momentum that led to today’s landmark decision. These laws were always a blatant attempt by authoritarian states to nullify Bruen and redline the right to bear arms out of existence. We are glad to see this issue put in the ground where it belongs. FPC will continue to Fight Forward until every immoral and unconstitutional restriction is eliminated throughout the United States.” — FPC President Brandon Combs
“This regime hobbles what the Second Amendment protects: the right of Americans to carry arms for self-defense as they go about their daily lives.” — Opinion of the Court
“[T]he Second Amendment has the same meaning in all parts of the United States. It cannot give way to ‘the spirit of Aloha’ in Hawaii any more than it can yield to the spirit of the Big Apple (Bruen) or the Windy City (McDonald). It applies in the same way to our 50th State (where about 8% of adults possess guns) and our 49th State (where the figure is roughly 59%). Merely local attitudes can neither shrink nor inflate the meaning of fundamental Bill of Rights guarantees that apply to the States through the Fourteenth Amendment.” (Cleaned up.) — Opinion of the Court
About Firearms Policy Coalition
Firearms Policy Coalition (FPC) is a nonprofit membership organization that exists to create a world of maximal individual liberty and eliminate unconstitutional gun control laws. FPC works—and wins—for the People through high-impact strategic litigation, groundbreaking research, legislative and regulatory advocacy, grassroots activism, education, and public engagement. FPC’s legal division, FPC Law, is the nation’s leading initiative dedicated to restoring the right to keep and bear arms across the United States. To learn more about how FPC is working—and winning—for the People, sign up for FPC news alerts at firearmspolicy.org and follow FPC on X, Instagram, and Facebook.
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