Two years after the Supreme Court’s New York State Rifle & Pistol Association, Inc. v. Bruen expanded gun rights, New York and firearms advocates are embroiled in a legal battle over where Americans can carry firearms in public.
The Firearms Policy Coalition (FPC), a leading national gun rights advocacy group, has taken another step in its ongoing legal battle against New York’s strict gun control measures. On May 20, 2025, FPC announced it had filed a reply brief with the federal Court of Appeals for the Second Circuit, challenging the state’s ban on carrying firearms in public parks.
This lawsuit, known as Christian v. James, is part of a broader fight over the scope of the Second Amendment in the wake of recent Supreme Court decisions.
The case cannot be fully understood without looking at the context of the Bruen decision. In this case, the Court struck down New York’s longstanding requirement that citizens show “proper cause” to obtain a concealed carry license. The ruling established that the Second Amendment protects an individual’s right to carry a firearm in public for self-defense. Most importantly, it set a new standard: gun laws must be consistent with the nation’s historical tradition of firearm regulation.
In response, New York enacted the Concealed Carry Improvement Act (CCIA), which dramatically expanded the list of “sensitive places” where guns are banned, which includes public parks, libraries, and even most private businesses unless they post explicit permission. Critics, including FPC, saw this as an attempt to flout the Supreme Court’s ruling and effectively maintain a near-total prohibition on the public carry of firearms.
FPC, joined by individual plaintiff Brett Christian and the Second Amendment Foundation, filed a lawsuit against these new restrictions. Their argument is straightforward: New York’s sweeping bans are the type of government overreach the Second Amendment was designed to prevent. In their recent brief, FPC asserts that the state cannot simply invent new categories of “sensitive places” to justify broad gun bans, especially when these restrictions lack clear historical precedent.
FPC President Brandon Combs did not mince words in his criticism: “New York responded to the Supreme Court’s Bruen decision by doing exactly what the Court said it could not and banned carry in most all public places. New York’s petulance and tyranny should be put to an end by the Second Circuit. We will continue to fight forward and eliminate unconstitutional laws like this so peaceable gun owners can fully exercise their rights when and how they choose.”
The state, for its part, argues that banning guns in public parks is consistent with a long tradition of regulating firearms in certain public spaces to protect public safety. The courts must now decide whether such modern restrictions can be justified under the historical test established by the Bruen decision.
The outcome of Christian v. James could have significant implications not just for New York, but for gun laws across the country. If the Second Circuit sides with FPC, it could limit states’ ability to designate broad swaths of public space as “sensitive” and off-limits to lawful gun owners. If the court upholds New York’s law, it may provide a roadmap for other states to impose similar restrictions, even after Bruen.
This case is one of many across the country testing the boundaries of the Supreme Court’s new Second Amendment framework. Since Bruen, federal courts have seen a surge in challenges to gun laws, and legal experts expect the Supreme Court to eventually clarify how far states can go in regulating the public carry of firearms.
Oral arguments in the case are scheduled for June 25, 2025. In the meantime, FPC is rallying supporters and raising awareness on this legal battle.
As FPC continues building its grassroots army and legal war chest, the Christian v. James case stands as a critical test of whether courts will enforce the Supreme Court’s expanded vision of gun rights.
About José Niño
José Niño is a freelance writer based in Austin, Texas. You can contact him via Facebook and X/Twitter. Subscribe to his Substack newsletter by visiting “Jose Nino Unfiltered” on Substack.com.
