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United States v. Rahimi

No. 22-915 SCOTUS · Decided SCOTUS
Argued: Nov 7, 2023 Decided: Jun 21, 2024

Second Amendment dangerousness exception historic traditions test

Legal Issues

Second Amendmentdangerousness exceptionhistoric traditions test

The Law · How the Case Works

Overview

Overview

Federal law prohibits anyone under a civil domestic violence restraining order from possessing a firearm. Zackey Rahimi, subject to such an order after assaulting his former girlfriend, was charged after firing guns in five separate incidents. He argued the law was unconstitutional under Bruen, which requires gun laws to have historical analogue from the founding era. The Supreme Court upheld the law 8-1, finding that disarming people who threaten others fits comfortably within the historical tradition of firearm regulation. Only Justice Thomas dissented.

The Rules

18 U.S.C. § 922(g)(8) The Federal Domestic-Violence Firearm Ban

Makes it a federal crime for a person subject to a qualifying domestic-violence restraining order to possess a firearm or ammunition. The order must have issued after notice and a hearing, must restrain the person from threatening, stalking, or harassing an intimate partner or child, and must either include a finding that the person "represents a credible threat to the physical safety" of that partner or child, or by its terms explicitly prohibit the use, attempted use, or threatened use of physical force against them.

U.S. Const. amend. II The Right to Keep and Bear Arms

"A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed."

N.Y. State Rifle & Pistol Assn. v. Bruen, 597 U.S. 1 (2022) The Text-and-History Test

A firearm law is constitutional only if the government shows it is consistent with the Nation's historical tradition of firearm regulation. Rahimi read Bruen narrowly on this point: the modern law need not be a "historical twin" or "dead ringer." A "historical analogue" that is analogous enough will do, because the test was never meant to be a "regulatory straightjacket."

District of Columbia v. Heller, 554 U.S. 570 (2008) An Individual Right, But Not Unlimited

The Second Amendment secures an individual right to keep and bear arms, but that right "is not unlimited." From the founding, the government could keep arms from those who would use them to harm others, and "longstanding prohibitions" on firearm possession remain "presumptively lawful."

The Conclusion

Conclusion

The Supreme Court upheld the federal domestic violence firearm ban 8-1 under the Second Amendment. Finding that disarming individuals subject to civil restraining orders for threatening others fits comfortably within the historical tradition of firearm regulation, the Court rejected Bruen-based constitutional challenges. Justice Thomas alone dissented.

The Record · 1 original document
CourtSupreme Court of the United States
FiledMar 21, 2023
CL StatusActive
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No circuit court data for this case.

Cert Granted -
StatusActive
Filed (CL)Mar 21, 2023
View on CourtListener →
SCOTUS TMR-08f9a5a8 Jul 28, 2026

Related Cases (2)

  • McDonald v. City of Chicago
    The opinion cites McDonald v. City of Chicago, 561 U.S. 742 (2010), for the principle that the Second Amendment right to keep and bear arms is fundamental to our system of ordered liberty.
  • Brown v. Davenport
    The opinion cites Brown v. Davenport for the principle that judicial language must be understood within its proper context and not stretched beyond its original meaning.

Related by Concept (1)

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