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Grace v. District of Columbia
Civil Action No. 2015-2234
| D.D.C. | Oct 17, 2017
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Background

  • The District of Columbia required applicants for concealed-carry licenses to show a "good reason" (a special need for self-defense) in order to obtain a permit under D.C. Code § 22-4506 and related regulations.
  • Plaintiffs challenged the "good reason" requirement as an unconstitutional burden on the Second Amendment right to carry firearms for self-defense outside the home.
  • The district court (Grace) preliminarily enjoined enforcement of the good-reason requirement, finding it likely unconstitutional.
  • The D.C. Circuit consolidated Grace with Wrenn and held that the good-reason law operated as a de facto total ban on carrying firearms for self-defense beyond the home.
  • The D.C. Circuit concluded the existing record was adequate, declined further factual development, and remanded with instructions to enter permanent injunctions against enforcement of the good-reason law.
  • Following denial of rehearing en banc and issuance of the mandate, the district court entered a permanent injunction consistent with the D.C. Circuit's instructions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether D.C.'s "good reason" requirement violates the Second Amendment right to carry firearms for self-defense outside the home The requirement unconstitutionally burdens the individual right to carry for self-defense beyond the home The law is a permissible regulatory restriction, not a total ban; it advances public safety The D.C. Circuit: the good-reason law functions as a total ban on the constitutional right to carry beyond the home and is therefore unconstitutional; permanent injunction ordered
Whether further factual development was necessary before a final remedy Plaintiffs: existing record sufficient to resolve constitutionality and enter permanent relief Defendant: additional factual development/remand needed to justify remedy The D.C. Circuit: additional development would be a waste of judicial resources; record was sufficient and remand should direct entry of permanent injunctions

Key Cases Cited

  • Wrenn v. District of Columbia, 864 F.3d 650 (D.C. Cir. 2017) (good-reason law is effectively a total ban on carrying firearms for self-defense beyond the home)
  • Grace v. District of Columbia, 187 F. Supp. 3d 124 (D.D.C. 2016) (preliminary injunction against D.C.'s good-reason requirement)
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Case Details

Case Name: Grace v. District of Columbia
Court Name: District Court, District of Columbia
Date Published: Oct 17, 2017
Docket Number: Civil Action No. 2015-2234
Court Abbreviation: D.D.C.