New York State Rifle & Pistol Assn., Inc. v. City of New York
590 U.S. 336
SCOTUS2020Background
- Petitioners (three individuals and an organization) sued NYC under 42 U.S.C. § 1983 challenging 38 N.Y.C.R.R. § 5-23, which barred NYC "premises" handgun licensees from transporting licensed handguns to shooting ranges, competitions, or second homes outside the City.
- NYC premises licenses involve extensive vetting; at the time there were only seven authorized in‑City ranges (most private), and the 2001 rule eliminated out‑of‑city "target" licenses.
- The District Court and Second Circuit upheld the travel restriction; the Supreme Court granted certiorari.
- After certiorari was granted, New York State amended its statute and NYC amended the rule to permit direct travel to out‑of‑city ranges/second homes with limits (e.g., travel must be "direct"; stops must be "reasonably necessary").
- The Supreme Court (per curiam) vacated the Second Circuit judgment and remanded for further proceedings, holding the original injunctive claim against the old rule moot; the Court left open whether petitioners may pursue damages or challenge the new rule. Justice Kavanaugh concurred on procedure; Justice Alito (joined by Gorsuch and partly Thomas) dissented, arguing the case was not moot and would have reached the Second Amendment merits and damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of injunctive claim against the old NYC rule | The repeal/amendment did not afford petitioners the full relief they sought ("unrestricted access") so case remains live | City: repeal/State law change moot the case; no need for further review of a rescinded rule | Per curiam: claim against the old rule is moot; judgment below vacated and case remanded for further proceedings on what remains live |
| Scope/meaning of the new rule (stops/en route activities) | Petitioners contend the new rule still restricts "unrestricted access" (e.g., ambiguous limits on "direct" travel and "reasonably necessary" stops) | City says routine stops (coffee, gas, restroom) are permitted and the new rule provides the relief sought | Supreme Court did not decide; remanded so lower courts can address disputes about the new rule in the first instance |
| Availability of damages for past enforcement of the old rule | Petitioners may recover nominal or compensatory damages under § 1983 despite not pleading damages expressly (complaint sought "other relief") | City argues it is too late to add a damages claim now and that the case is moot as to past conduct | Per curiam: did not decide; remanded so Courts of Appeals/District Court may consider whether petitioners can seek damages; dissent argued damages keep case live and would remand for relief |
| Second Amendment merits of the travel restriction | Petitioners: travel to ranges/competitions is necessary to maintain proficiency and is a right incident to the core home‑defense right recognized in Heller | City: restriction is justified by public‑safety interests and administrative enforceability; lower courts applied heightened scrutiny and upheld the rule | Per curiam: did not reach the merits. In dissent, Justice Alito would have found the ordinance unconstitutional under Heller and remanded for relief |
Key Cases Cited
- District of Columbia v. Heller, 554 U.S. 570 (2008) (recognized individual right to keep handgun in the home for self‑defense)
- McDonald v. Chicago, 561 U.S. 742 (2010) (applied Heller Second Amendment holdings to the States)
- Lewis v. Continental Bank Corp., 494 U.S. 472 (1990) (guidance on vacatur/remand when legal landscape changes post‑decision)
- Chafin v. Chafin, 568 U.S. 165 (2013) (mootness standard: case moot only if no effectual relief can be granted)
- Carey v. Piphus, 435 U.S. 247 (1978) (nominal damages available for constitutional violations)
- Buckhannon Board & Care Home, Inc. v. West Virginia Dept. of Health & Human Resources, 532 U.S. 598 (2001) (prevailing‑party fees and limits on voluntary‑cessation mootness defenses)