In a move that’s sent shockwaves through the Second Amendment debate, the U.S. Supreme Court declined to hear two high-profile challenges to state gun-control laws — one in Maryland, the other in Rhode Island — leaving in place lower court rulings that uphold bans on semiautomatic assault-style weapons and large-capacity magazines.
This decision, made after 15 consecutive conferences of deliberation, has left both proponents and opponents of gun control parsing through signals sent by individual justices. The refusal to grant certiorari (take up the case) was notable not only for its silence but also for its potential implications for future legal battles around firearms regulation in the post-Bruen era.
Case 1: Snape v. Brown (Maryland’s Assault Weapons Ban)
At the heart of Snape v. Brown was Maryland’s 2013 Firearm Safety Act, which bans so-called assault weapons such as the AR-15 and AK-47. Enacted in the aftermath of the Sandy Hook Elementary tragedy, this law sought to prevent further mass shootings by restricting access to high-powered semi-automatic rifles.
The challengers argued that these firearms are “in common use” and thus protected by the Second Amendment under the precedent set by District of Columbia v. Heller (2008). They emphasized that AR-15s are among the best-selling rifles in the United States, used by millions of law-abiding citizens for lawful purposes including self-defense.
However, the Fourth Circuit Court of Appeals upheld Maryland’s law. Writing for the majority, Judge J. Harvie Wilkinson asserted that these weapons are fundamentally military in design and not suited for civilian self-defense. Even if protected by the Second Amendment, he argued, Maryland’s restrictions fall within the nation’s longstanding tradition of regulating dangerous weapons.
A strong dissent came from Judge Julius Richardson and four colleagues, arguing that the ban unconstitutionally restricts arms “indisputably” protected under the Second Amendment. They challenged the majority’s interpretation of “dangerous and unusual weapons,” contending that such terms don’t apply to firearms commonly owned and used by the public.
When the case reached the Supreme Court, Justices Clarence Thomas, Samuel Alito, and Neil Gorsuch expressed their desire to grant the petition. Justice Brett Kavanaugh issued a notable statement — although he voted against hearing the case now, he warned that the issue was ripe for review. With conflicting rulings developing across different circuits, Kavanaugh suggested the Court would likely address the AR-15 question in a future term.
Justice Thomas went further, criticizing lower courts for “distorting” the Supreme Court’s Second Amendment rulings, particularly after the landmark decision in New York State Rifle & Pistol Association v. Bruen (2022). In Bruen, the Court clarified that only regulations consistent with the historical tradition of firearm laws are constitutional — a standard which, Thomas argued, Maryland’s ban could not meet.
Case 2: Ocean State Tactical v. Rhode Island (Ban on Large-Capacity Magazines)
The second case involved Rhode Island’s 2022 law banning magazines that hold more than 10 rounds of ammunition. Passed shortly after the tragic mass shooting in Uvalde, Texas, the law gave residents six months to modify, surrender, sell, or transfer their high-capacity magazines.
Gun owners challenged the law under both the Second and Fifth Amendments. They argued that the ban restricts arms commonly owned for lawful purposes and constitutes an unconstitutional taking of property without just compensation. They claimed that courts misapplied the Bruen standard by evaluating how burdensome the law is, rather than whether it aligns with historical firearm regulations.
The First Circuit, however, upheld the law. It reasoned that the ban imposes no “meaningful burden” on the right to bear arms, as civilians rarely need more than 10 rounds for self-defense. Moreover, the court drew historical parallels to restrictions on sawed-off shotguns and stockpiling gunpowder, citing the government’s longstanding authority to regulate arms that pose unique threats to public safety.
Rhode Island defended the law vigorously, arguing that magazines are accessories, not protected “arms.” The state also emphasized that allowing uninterrupted rapid fire, especially during mass shootings, increases the danger to the public, while requiring smaller magazines provides crucial moments for escape or intervention.
The Supreme Court again declined to intervene, though Thomas, Alito, and Gorsuch signaled they would have reviewed the challenge.
Legal Implications and What’s Next
While these decisions do not create binding precedent at the national level, they send a strong message: the Supreme Court is not yet ready to wade back into Second Amendment litigation involving assault weapons and high-capacity magazines, despite considerable circuit-level disagreement and public interest.
These denials are also instructive in understanding internal Court dynamics. The fact that at least four justices (the number required to hear a case) didn’t agree to take up the challenges — despite several signaling strong disagreement with lower courts — suggests a strategic delay. The Court may be waiting for a more fully developed circuit split or a different factual record before taking on a major gun rights case post-Bruen.
For law students and legal practitioners, this moment highlights the evolving nature of Second Amendment jurisprudence. It also serves as a case study in how lower courts interpret major Supreme Court precedents — and how justices choose when to intervene.
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Source: https://www.scotusblog.com/2025/06/supreme-court-declines-to-hear-gun-control-challenges/
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