N. Randy Smith

Rule Changes

Dissented in Baird v. Bonta

The Ninth Circuit just struck down California's ban on openly carrying guns in urban areas, ruling that a law affecting 95% of the state violates the Second Amendment. Judge Lawrence VanDyke wrote that open carry was widely protected at America's founding—exactly the kind of historical analysis the Supreme Court demanded in its 2022 Bruen decision. The ruling creates a circuit split with the Second Circuit, which said states can ban one form of carry as long as they allow the other.

Updated Jan 21