Peruta v. California, 137 S. Ct. 1995

California generally bans open carry and requires a "good cause" license for concealed carry; counties may define "good cause."
San Diego County sheriff requires a particularized, documentable need for self‑defense; generalized fear of crime is insufficient.
Petitioners (San Diego residents and an association) sued under 42 U.S.C. §1983 seeking declaratory and injunctive relief, arguing the scheme effectively bans public carry in violation of the Second Amendment.
A Ninth Circuit panel held that the Second Amendment protects carrying operable handguns outside the home for self‑defense and that the sheriff’s policy violated the Amendment (742 F.3d 1144).
The Ninth Circuit granted en banc rehearing and reversed the panel, holding the Second Amendment does not protect a public right to carry concealed firearms (824 F.3d 919).
The Supreme Court denied certiorari; Justice Thomas (joined by Justice Gorsuch) dissented from that denial, arguing the Court should resolve whether the Second Amendment protects public carry.

Issue	Peruta (Plaintiff) Argument	California (Defendant) Argument	Held
Whether the Second Amendment protects the right to carry firearms in public for self‑defense	Second Amendment includes "bear" arms outside the home; public carry for self‑defense is protected	States may regulate or restrict public carry; licensing schemes like "good cause" are permissible	Supreme Court denied certiorari; Ninth Circuit en banc held no protected right to carry concealed firearms. Justice Thomas would have granted review and held the Amendment protects some form of public carry.
Whether San Diego sheriff’s "good cause" concealed‑carry policy violates the Second Amendment	Sheriff’s particularized‑need rule amounts to a practical ban on public carry and therefore infringes the right to bear arms	Policy is a lawful regulatory requirement distinguishing general fear from particularized risk	Ninth Circuit en banc upheld the sheriff’s policy (no constitutional protection for concealed public carry); panel had ruled the policy violated the Second Amendment. Supreme Court denied review; Justice Thomas dissented.

District of Columbia v. Heller, 554 U.S. 570 (2008) (Second Amendment protects an individual right to possess firearms for self‑defense)
Muscarello v. United States, 524 U.S. 125 (1998) (defining "bear arms" to mean carry upon the person)
McDonald v. City of Chicago, 561 U.S. 742 (2010) (Second Amendment incorporated against the States)
Peruta v. County of San Diego, 742 F.3d 1144 (9th Cir. 2014) (panel: public carry for self‑defense is protected; sheriff’s policy invalid)
Peruta v. County of San Diego, 824 F.3d 919 (9th Cir. 2016) (en banc: Second Amendment does not protect a public right to carry concealed firearms)
Nunn v. State, 1 Ga. 243 (1846) (historical precedent striking down an open‑carry ban while upholding a concealed‑carry prohibition)
State v. Reid, 1 Ala. 612 (1840) (historical discussion that regulatory schemes destroying the right to bear arms would be unconstitutional)