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The U.S. Supreme Court handed gun owners another major Second Amendment victory Thursday, striking down Hawaii’s so-called “Vampire Rule” and making clear that states cannot flip centuries of property law to sidestep Bruen.
In a 6-3 decision in Wolford v. Lopez, the Court ruled Hawaii violated the Second and Fourteenth Amendments by prohibiting licensed concealed carriers from bringing firearms onto private property open to the public unless the owner gave express permission.
Justice Samuel Alito, writing for the majority, was rather direct.
This regime hobbles what the Second Amendment protects: the right of Americans to carry arms for self-defense as they go about their daily lives,” Alito wrote.
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Hawaii Flipped the Default
Before the law, Hawaii followed the same common-law rule used throughout the country: businesses open to the public were presumed open unless the owner told someone to leave.
After Bruen, Hawaii flipped that rule on its head.
Instead of allowing licensed carriers to enter unless firearms were prohibited, the state required businesses to post signs expressly allowing concealed carry or give individual permission. Without it, entering armed became a crime.
The Court said that burden was unconstitutional.
Alito illustrated the problem by describing a woman with a valid carry permit trying to go about an ordinary day. Filling up at a gas station, grabbing lunch, shopping for groceries, or stopping at a dry cleaner could all expose her to criminal liability unless every business had posted “Guns Welcome” signs or someone in authority granted permission.
‘The Spirit of Aloha’ Doesn’t Override the Constitution
One of the opinion’s most memorable passages rejected Hawaii’s argument that its unique history and culture justified the restriction.
“The Second Amendment cannot give way to ‘the spirit of Aloha’ in Hawaii,” Alito wrote, “any more than it can yield to the spirit of the Big Apple or the Windy City.”
The Court emphasized that constitutional rights do not change from state to state simply because local officials have different attitudes toward firearms.
It also rejected Hawaii’s historical arguments, including attempts to justify the law with colonial anti-poaching statutes and even an 1865 Louisiana Black Code that disarmed newly freed Black Americans. The Court called reliance on that law impossible to take seriously as evidence of the Second Amendment’s original meaning.
Another Bruen Rebuff
The decision builds directly on New York State Rifle & Pistol Association v. Bruen, which held that law-abiding Americans have a constitutional right to carry handguns in public for self-defense.
According to the majority, Hawaii responded by replacing one unconstitutional restriction with another. Rather than denying permits outright, the state effectively made most ordinary destinations off-limits for permit holders.
Media reports indicate the ruling also casts serious doubt on nearly identical laws enacted in California, Maryland, New Jersey, and New York.
SAF, CCRKBA Celebrate
The Citizens Committee for the Right to Keep and Bear Arms, which joined an amicus brief alongside the Second Amendment Foundation, praised the ruling as another major victory for gun owners.
We have always held that the right to keep and bear arms does not end at someone’s front door,” said CCRKBA Chairman Alan Gottlieb. “People have a right to carry firearms in public for personal protection, and that includes shopping malls, supermarkets, hotels, gas stations and other places.”
Gottlieb added that if a business wants to prohibit firearms, “the responsibility for posting that falls on the establishment,” not the law-abiding citizen.
He also said the decision should prompt states with restrictive carry laws to “seriously re-evaluate not only their statutes, but their traditional animus toward the Second Amendment.”
The ruling marks another significant chapter in the Supreme Court’s post-Bruen Second Amendment jurisprudence, reinforcing that states cannot accomplish indirectly what the Constitution forbids them from doing directly.
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is a seasoned outdoorsman, lifelong hunter, and the kind of guy who’d rather track whitetails than scroll social media. As an editor for GunsAmerica, he’s got a sharp eye for spotting both solid gear and bad gun laws. Whether he’s deep in the woods or deep in editorial deadlines, Larry brings a no-nonsense, tell-it-like-it-is approach to firearms, hunting, and the great American tradition of self-reliance. If there’s a hot debate on gun rights or the latest in hunting tech, you can bet Larry’s got an opinion—and it’s probably backed up with both facts and field experience.
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– Concealed Carry Permit Holder (NYS & AZ) – Trained and licensed to carry in multiple states.
– 2A Journalist – Covering firearms legislation, Second Amendment issues, and gun rights for over a decade.
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