Why did the Supreme Court strike down New York’s proper-cause requirement for concealed-carry permits in New York State Rifle & Pistol Association v. Bruen?

In New York State Rifle & Pistol Association v. Bruen (2022), the U.S. Supreme Court struck down New York’s "proper-cause" requirement for concealed-carry permits because it violated the Second Amendment.12

The Court determined that the state’s licensing regime was unconstitutional because it issued public-carry licenses only to applicants who could demonstrate a "special need for self-defense". In the majority opinion, Justice Clarence Thomas explained that this requirement did not sufficiently resemble the historical regulations that were in place when the Second Amendment was adopted. The Court established that for contemporary gun laws to be constitutional, they must be "relevantly similar" to historical regulations that the nation's regulatory tradition is understood to permit.123

By requiring individuals to prove a specific need beyond the general right to self-defense, New York’s "may-issue" system placed an unconstitutional burden on the exercise of the right to bear arms, effectively shifting the state toward a "shall-issue" standard.2