The Supreme Court's June decision in Wolford v. Lopez prevented the obliteration of the right to bear arms in five States, holding that governments may not make carrying a licensed handgun presumptively illegal almost everywhere. 609 U.S. 185 (2026). Important as the result is, perhaps of even greater significance is how Wolford clarified Second Amendment doctrine. According to Wolford:
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Determining whether a challenged law falls within the "plain text" of the Amendment is much simpler than some lower courts and gun control advocates have claimed.
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Modern gun control laws do not always have to be justified by analogies from past practices, but analogies cannot be based on oddities and outliers.
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Racist gun control laws from the past, which were long ago repudiated by constitutional amendment, are not valid precedents for infringing the rights of modern Americans.
This essay will also discuss the Hawaii Attorney General's argument that only a weak version of the Second Amendment should apply in the Aloha State. And the argument that Hawaii's "Vampire Rule" to prohibit licensed carry throughout the State did not even implicate the Second Amendment.
