HANSON v. DISTRICT OF COLUMBIA, 671 F.Supp.3d 1

Background

Plaintiffs are four D.C. residents who hold concealed-carry licenses and seek to possess large-capacity magazines (LCMs, magazines that hold >10 rounds) in the District; one plaintiff (Yzaguirre) was denied firearm registration because of a 12‑round magazine.
D.C. law (D.C. Code § 7-2506.01(b)) bans possession, sale, or transfer of magazines that accept more than 10 rounds; violation carries criminal penalties.
Plaintiffs moved for a preliminary injunction (and sought permanent relief) arguing the ban violates the Second Amendment under the Bruen framework.
The court found at least one plaintiff likely has standing (Yzaguirre) but concluded plaintiffs were unlikely to succeed on the merits and denied the preliminary injunction.
On the merits the court held (1) LCMs are "arms" but are not covered by the Second Amendment because they are "most useful in military service" and are not typically used for self-defense; and (2) alternatively, the ban is consistent with the Nation’s historical tradition (Prohibition‑era high‑capacity and machine‑gun regulations).

Issues

Issue	Plaintiffs' Argument	District's Argument	Held
Standing to seek injunction	Plaintiffs: all four have concrete injury from the ban	Dist.: did not contest; court must require substantial likelihood of standing	Court: at least Yzaguirre likely has standing (registration denial); suffices to reach merits
Are LCMs "arms" under the Second Amendment?	Plaintiffs: magazines are necessary to render firearms operable and thus are "arms"	Dist.: magazines are accoutrements/accessories, not protected "arms"	Court: agrees LCMs are "arms" (follows persuasive circuit authority)
Are LCMs typically possessed for lawful purposes (self-defense)?	Plaintiffs: LCMs are commonly owned and used lawfully (self‑defense, sport, training)	Dist.: LCMs are most useful in military/law enforcement; civilians rarely fire >10 rounds in defense (avg ~2 shots)	Court: LCMs are not typically possessed for self-defense and are "most useful in military service," so not covered by the Second Amendment
If within Second Amendment, is the ban consistent with historical tradition (Bruen step 2)?	Plaintiffs: modern LCM bans lack Founding-era analogues; 20th‑century laws irrelevant or outlier	Dist.: there are historically relevant analogues—Prohibition‑era and 1920s–30s high‑capacity/machine‑gun laws regulating capacity and possession; modern public‑safety justification comparable	Court: even assuming coverage, D.C. met its burden: Prohibition‑era bans and related history are sufficiently analogous; the regulation is consistent with historical tradition

Key Cases Cited

District of Columbia v. Heller, 554 U.S. 570 (2008) (recognizes individual right to possess arms for self‑defense while acknowledging limits)
New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 142 S. Ct. 2111 (2022) (announces test: text first, then historical‑tradition inquiry)
Heller v. District of Columbia (Heller II), 670 F.3d 1244 (D.C. Cir. 2011) (upheld D.C. LCM ban under two‑step framework; discussed common‑use evidence)
Ass'n of New Jersey Rifle & Pistol Clubs, Inc. v. Attorney General New Jersey, 910 F.3d 106 (3d Cir. 2018) (held magazines are "arms")
Kolbe v. Hogan (en banc), 849 F.3d 114 (4th Cir. 2017) (held LCMs "most useful in military service" and not protected)
Duncan v. Bonta (en banc), 19 F.4th 1087 (9th Cir. 2021) (discussed military utility of LCMs and empirical evidence re: self‑defense use)
New York State Rifle & Pistol Ass'n v. Cuomo, 804 F.3d 242 (2d Cir. 2015) (analyzed common‑use and public‑safety evidence regarding LCMs)