The Supreme Court is gearing up for a major Second Amendment showdown — and attorney Alan Beck is ready to drive a stake through the heart of Hawaii’s so-called “Vampire Rule.”
This case, Wolford v. Lopez, challenges a Hawaii law that bans lawful concealed carry on all private property by default — unless the property owner explicitly says it’s allowed. That means gun owners can’t carry anywhere open to the public, even with a permit, unless the business posts a sign or personally invites them to.
As Beck explained in his interview with Cam Edwards on Bearing Arms, this rule flips centuries of American legal tradition upside-down.
What Is the “Vampire Rule”?
The name fits.
Just like a vampire can’t enter a home without being invited, gun owners in Hawaii can’t carry their firearms into stores, restaurants, or businesses unless the owner gives permission.
Across most of America, the rule works the other way: you can carry unless the property owner opts out. Only five states — Hawaii, New York, New Jersey, Maryland, and California — have adopted this “invite-only” rule, all after the Supreme Court’s 2022 Bruen decision that affirmed the right to carry firearms in public.
Hawaii’s politicians responded by doing everything possible to neuter that ruling. “If they can’t deny you a carry permit anymore,” Beck explained, “they’ll just make sure there’s nowhere left to carry.”
96% of Maui Off-Limits
Beck’s clients — the Wolfords and the Hawaii Firearms Coalition — have shown that under Hawaii’s 2023 law (Act 52), an estimated 96.4% of Maui’s publicly accessible land is now considered a “sensitive place.”
That includes beaches, parks, banks, and nearly every restaurant that serves alcohol — which, as Beck joked, “is basically every diner in Maui.”
The result? Ordinary citizens who went through the process of getting concealed carry permits are effectively disarmed everywhere they go.
A Law With Ugly Roots
Incredibly, the Ninth Circuit upheld Hawaii’s law by citing just two historical “precedents”:
- A 1771 New Jersey anti-poaching law, and
- An 1865 Louisiana “Black Code” designed to stop freed slaves from carrying guns.
Beck didn’t mince words: “That’s not a proud American tradition — that’s discrimination dressed up as precedent.”
The Supreme Court now has the chance to correct that mistake and clarify once and for all that the right to bear arms applies in ordinary public spaces — not just where the government approves.
What’s at Stake
The Wolford case is the first major post-Bruen test of how far states can go in declaring “sensitive places.” A victory here could strike down similar bans in other blue states, reaffirming that the Second Amendment isn’t a second-class right.
If Hawaii’s law falls, it will send a message nationwide: states cannot use “backdoor” property rules to gut the right to carry.
What Happens Next
Beck’s opening brief to the Supreme Court is due within weeks. Oral arguments are expected this winter — possibly as early as December — and a decision could come by summer 2026.
Dozens of pro-gun organizations, including Gun Owners of America, the Second Amendment Foundation, and National Association for Gun Rights, have filed briefs backing Beck and his clients.
If they win, it will free Hawaii’s gun owners and help roll back the wave of post-Bruen defiance spreading through blue-state legislatures.
Final Thoughts
The “Vampire Rule” is a perfect symbol of how far some states will go to drain the life out of the Second Amendment. But thanks to Alan Beck and others fighting on the front lines, the tide may finally be turning.
The Supreme Court’s decision in Wolford v. Lopez could drive the stake home — restoring the right to carry where it belongs: with the people.
If you value your right to bear arms, follow Bearing Arms and attorney Alan Beck for updates as this landmark case unfolds. Like, share, and spread the word — sunlight is the best cure for bad laws.
