Hawaii's concealed-carry policy, which was not at issue in Young, was similarly restrictive. Young involves Hawaii's highly restrictive carry permit policy, which requires that applicants demonstrate 'the urgency or the need' to carry unconcealed firearms, that they have 'good moral character,' and that they are 'engaged in the protection of life and property.' As interpreted by Hawaii County (the 'Big Island'), those standards limit open-carry permits to 'private detectives and security guards.'

Hawaii, a 9th Circuit case, bears the closest resemblance to the facts in Bruen. The majority opinion by Justice Clarence Thomas, which was joined by five other justices, also clarified the constitutional test for gun regulations, rejecting 'interest-balancing' standards in favor of a historical approach that asks whether a challenged law is analogous to restrictions that have traditionally been viewed as consistent with the right to keep and bear arms. In Bruen, the Court said New York's restrictions on carrying concealed handguns in public, which required 'proper cause' for a permit, violated the Second Amendment. The remanded cases involve Hawaii's restrictions on carrying guns for self-defense, California's 10-round magazine limit, a similar New Jersey law, and Maryland's 'assault weapon' ban. The Supreme Court yesterday vacated four appeals court decisions upholding gun control laws, remanding the cases for reconsideration in light of its decision last week in New York State Rifle & Pistol Association v.

Scotus decisions