N.Y. State Rifle & Pistol Ass'n v. City of N.Y. - 140 S. Ct. 1525 (2020)

Rule:

Our ordinary practice in disposing of a case that has become moot on appeal is to vacate the judgment with directions to dismiss. See, e.g., Deakins v. Monaghan, 484 U. S., at 204, 108 S. Ct. 523, 98 L. Ed. 2d 529; United States v. Munsingwear, Inc., 340 U. S. 36, 39-40, 71 S. Ct. 104, 95 L. Ed. 36 (1950). However, in instances where the mootness is attributable to a change in the legal framework governing the case, and where the plaintiff may have some residual claim under the new framework that was understandably not asserted previously, our practice is to vacate the judgment and remand for further proceedings in which the parties may, if necessary, amend their pleadings or develop the record more fully. See Diffenderfer v. Central Baptist Church of Miami, Inc., 404 U. S. 412, 415, 92 S. Ct. 574, 30 L. Ed. 2d 567 (1972).”

Facts:

In the District Court, petitioners challenged a New York City rule regarding the transport of firearms. Petitioners claimed that the rule violated the Second Amendment. Petitioners sought declaratory and injunctive relief against enforcement of the rule insofar as the rule prevented their transport of firearms to a second home or shooting range outside of the city. The District Court and the Court of Appeals rejected petitioners’ claim.  After the certiorari was granted, the State of New York amended its firearm licensing statute, and the City amended the rule so that petitioners may now transport firearms to a second home or shooting range outside of the city, which is the precise relief that petitioners requested in the prayer for relief in their complaint. Petitioners’ claim for declaratory and injunctive relief with respect to the City’s old rule was therefore moot. Petitioners argued, however, that the new rule may still infringe their rights. In particular, petitioners claimed that they may not be allowed to stop for coffee, gas, food, or restroom breaks on the way to their second homes or shooting ranges outside of the city. The City responded that those routine stops are entirely permissible under the new rule. Petitioners further argued that they may still seek damages in this lawsuit even if they had not previously asked for damages with respect to the City’s old rule.

Issue:

Was the claim in a case already declared moot valid?

Answer:

Yes.

Conclusion:

In instances where the mootness is attributable to a change in the legal framework governing the case, and where the plaintiff may have some residual claim under the new framework that was understandably not asserted previously, our practice is to vacate the judgment and remand for further proceedings in which the parties may, if necessary, amend their pleadings or develop the record more fully. It was held that the court may consider whether petitioners may still add a claim for damages in this lawsuit with respect to New York City’s old rule.