NRA-ILA | 2025 Litigation Update

In 2025, the National Rifle Association defeated New Mexico’s 7-day waiting period for firearm purchases, the ATF’s “engaged in the business” rule, the ATF’s “pistol brace” rule, a lawsuit seeking to ban lead ammunition in the Canaan Valley NWR, and in a case now being reheard by the en banc Ninth Circuit, California’s background check requirement for ammunition purchases. NRA filed 10 new cases; 3 petitions for certiorari in the U.S. Supreme Court; and 20 amicus briefs, including 9 in the U.S. Supreme Court. NRA counsel also published three law review articles, hosted webinars to discuss our litigation efforts across the country, and continued its Legal Scholar Video Series, all while litigating dozens of other cases across the country.

Litigation Victories

Ortega v. Grisham – The Tenth Circuit Court of Appeals held that New Mexico’s 7-day waiting period for firearm purchases violates the Second Amendment in August 2025. The state petitioned for rehearing en banc, but the court denied that petition last week.

Butler v. ATF – In October 2025, an Alabama federal district court held that the ATF exceeded its statutory authority by issuing its 2024 Final Rule expanding the definition of being “engaged in the business” of “dealing in firearms,” and permanently enjoined the ATF and the DOJ from enforcing several of the Final Rule’s provisions against NRA members.

Rhode v. Bonta – The Ninth Circuit Court of Appeals struck down California’s background check requirement for ammunition purchases in July 2025. But the court voted to rehear the case en banc in December 2025. En banc oral argument has been scheduled for the week of March 23, 2026.

NRA v. ATF & FRAC v. ATF – After defeating the ATF’s “pistol brace” rule in the Eighth Circuit Court of Appeals in FRAC v. ATF, the ATF conceded that its rule was unenforceable and these two challenges were resolved.

National Wildlife Refuge Association v. Haaland – The plaintiffs dismissed their lawsuit—in which the NRA intervened—that aimed to ban lead ammunition in the Canaan Valley National Wildlife Refuge.

New Cases

Brown v. ATF – a challenge to the National Firearms Act of 1934’s restrictions on suppressors, short-barreled long guns, and NFA-defined “any other weapons,” filed in Missouri.

Jensen v. ATF – an NRA-supported challenge to the National Firearms Act of 1934’s restrictions on suppressors, short-barreled long guns, and NFA-defined “any other weapons,” filed in Texas.

Hanlon v. Campbell – a challenge to Massachusetts’s ban on “assault-style firearms.”

Escher v. Noble – a challenge to Massachusetts’s law prohibiting adults under 21 from possessing or carrying any handgun or semiautomatic firearm.

Jaymes v. Bonta – a challenge to California’s ban on Glock-style handguns.

Padua v. Platkin – a challenge to New Jersey’s ban on suppressors.

Struck v. Platkin – a challenge to New Jersey’s “one-gun-a-month” restriction.

Dunn v. Glass – a challenge to Florida’s 3-day waiting period requirement for firearm purchases.

Langston v. Humphreys – a challenge to Colorado’s excise tax on firearm and ammunition sales. 

Sportsmen’s Alliance Foundation v. BLM – a challenge to the Bureau of Land Management’s shooting ban on the Sonoran Desert National Monument.

Cert Petitions

NRA v. Glass – NRA petitioned the Supreme Court to hear its challenge to Florida’s ban on firearm purchases by adults under 21. Florida responded to the petition by urging the Court to hear the case and rule its own law unconstitutional. The Court distributed the petition for the November 14, 2025, conference, and has not yet ruled on it.

Duncan v. Bonta – A petition for certiorari was filed urging the Supreme Court to hear this NRA-supported challenge to California’s prohibition and confiscation of magazines that hold over 10 rounds. The Court first distributed the petition for the December 5, 2025, conference, and then redistributed it for the December 12, 2025, conference, and has not yet ruled on it.

Rush v. United States – NRA-ILA counsel petitioned the Supreme Court to hear a challenge to the National Firearms Act of 1934’s tax and registration requirements for short-barreled rifles. The Court denied the petition on December 15, 2025.

Ongoing Litigation Highlights

Barnett v. Raoul – After the district court struck down Illinois’s bans on “assault weapons” and “large-capacity magazines” last year, the state appealed to the Seventh Circuit Court of Appeals, which heard oral argument on September 22, 2025. The U.S. Department of Justice filed an amicus brief on behalf of the United States supporting our challenge, and also participated in oral argument.

ANJRPC v. Platkin – A 3-judge panel of the Third Circuit Court of Appeals heard oral argument in our challenge to New Jersey’s bans on “assault firearms” and “large-capacity magazines” on July 1, 2025. But before the panel issued a decision, the full court sua sponte took the case en banc. En banc argument occurred on October 15, 2025. The DOJ also filed a brief on behalf of the United States supporting us in this challenge.

Siegel v. Platkin (consolidated with Koons v. Platkin) – In response to the NRA’s landmark Supreme Court victory, NYSRPA v. Bruen, New Jersey passed a “Bruen-response” law making it illegal to carry a firearm in 26 categories and 115 subcategories of places that together cover nearly every square inch of public space throughout the state. The law also includes several other restrictions, including a requirement that carry-permit applicants provide references from four “reputable” non-relatives. A 3-judge panel of the Third Circuit Court of Appeals upheld most of the law, but the court granted our petition for rehearing en banc on December 11, 2025. Oral argument is scheduled for February 11, 2026.

Kipke v. Moore – The Fourth Circuit Court of Appeals heard oral argument in our challenge to Maryland’s “Bruen-response” law on May 7, 2025.

Amicus Briefs

The NRA filed amicus briefs in the following cases in 2025:

Wolford v. Lopez (Supreme Court – merits) – challenge to Hawaii’s private property default carry ban.

Wolford v. Lopez (Supreme Court – petition) – challenge to Hawaii’s private property default carry ban.

B&L Productions, Inc. v. Newsom (Supreme Court) – challenge to California’s ban on gun shows held on state property.

Antonyuk v. James (Supreme Court) – challenge to New York’s Concealed Carry Improvement Act, which restricts carry throughout the state.

Hanson v. District of Columbia (Supreme Court) – challenge to Washington D.C.’s magazine ban.

Vincent v. Bondi (Supreme Court) – challenge to the federal prohibition on firearms possession by nonviolent felons.

Gator’s Custom Guns v. Washington (Supreme Court) – challenge to Washington’s ban on magazines that hold over 10 rounds.

Zherka v. Bondi (Supreme Court) – challenge to the federal prohibition on firearms possession by nonviolent felons. 

Gardner v. Maryland (Supreme Court) – challenge to Maryland’s carry restrictions for nonresidents.

Duarte v. United States (Supreme Court) — challenge to the federal prohibition on firearms possession by nonviolent felons.

Beckwith v. Frey (First Circuit) – challenge to Maine’s 3-day waiting period requirement for firearm purchases.

Calce v. Tisch (Second Circuit) – challenge to New York City’s stun gun ban.

Vermont Federation of Sportsmen’s Clubs v. Birmingham (Second Circuit) – challenge to Vermont’s 3-day waiting period requirement for firearm purchases.

Lowy v. Daniel Defense (Fourth Circuit) – lawsuit attempting to hold firearm manufacturers liable for criminal violence based on pro-Second Amendment speech.

United States v. Peterson (Fifth Circuit) – challenge to the NFA’s restrictions on suppressors. 

Knife Rights, Inc v. Bondi (Fifth Circuit) – challenge to the Federal Switchblade Act. 

United States v. Brown (Fifth Circuit) – challenge to the federal prohibition on machinegun possession.

Schoenthal v. Raoul (Seventh Circuit) – challenge to Illinois’s ban on carrying on public transportation.

Knife Rights, Inc. v. Bonta (Ninth Circuit) – challenge to California’s switchblade ban.

Gun Owners of America v. Philadelphia (PA Supreme Court) – challenge to a prohibition on the private manufacture of firearms.

Law Review Articles

NRA-ILA Litigation Director Joseph Greenlee, David Kopel, and Bhav Nindar Singh published an article in the South Texas Law Review entitled, The Social Cost of Nullifying the Right to Arms: The Case of Mexico. The article: (1) describes the cartel crime problem in Mexico and how the Mexican government has often made it worse; (2) examines the nullification of Mexico’s constitutional right to arms; (3) looks at the Mexican government’s suppression of community defense militias; and (4) details the evidence that American-made firearms lawfully sold in America have little if anything to do with Mexico’s crime problems.

Greenlee and former NRA President Bob Barr published an article in the Penn State Dickinson Law Review entitled, When Rights Require Permission: The Discriminatory History of Licensing Laws for Firearm Possession. The article explores the historical tradition of regulations requiring a permit to possess firearms and applies the Supreme Court’s test to determine whether modern permitting laws violate the Second Amendment.

Greenlee also published an article in the University of Wyoming Law Review entitled, The Tradition of Short-Barreled Rifle Use and Regulation in America. The article: (1) describes many short-barreled rifles from the nineteenth century and their predecessors from the colonial and founding eras; (2) analyzes the historical regulations relevant to short-barreled rifles; and (3) applies the Supreme Court’s Second Amendment doctrine to modern regulations on short-barreled rifles.

Legal Scholar Video Series

For the NRA’s Legal Scholar Video Series, Greenlee interviewed historian and constitutional scholar Joyce Lee Malcolm about her book, To Keep and Bear Arms: The Origins of an Anglo-American Right; legal historian Robert Cottrol about his book, To Trust the People with Arms: The Supreme Court and the Second Amendment; and Law Professor George Mocsary about his article Treating Young Adults as Citizens.

Interviews and Speeches

NRA-ILA counsel discussed ILA’s litigation efforts on numerous radio shows and podcasts, including American Family Radio, America’s 1st Freedom, 2A News, Armed American Radio, Arms Room Radio, Beyond the Bench, and Cam & Company. NRA-ILA counsel also taught Continuing Legal Education courses in Georgia, Wyoming, and Delaware, and presented at the Second Amendment Foundation’s Gun Rights Policy Conference.

Webinars

NRA-ILA counsel held webinars to discuss our litigation efforts in New Jersey, Washington, and Illinois, in addition to a nationwide webinar.

Please stay tuned to www.nraila.org for future updates on NRA-ILA’s ongoing efforts to defend your constitutional rights, and please visit www.nraila.org/litigation to keep up to date on NRA-ILA’s ongoing litigation efforts.