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The core prohibitions by New York and Connecticut of assault weapons and large-capacity magazines do not violate the Second Amendment.
Two appeals were challenging gun-control legislation enacted by the New York and Connecticut legislatures in the wake of the 2012 mass murders at Sandy Hook Elementary School in Newtown, Connecticut. The New York and Connecticut laws at issue prohibit the possession of certain semiautomatic "assault weapons" and large-capacity magazines. Following the entry of summary judgment in favor of defendants on the central claims in both the Western District of New York and the District of Connecticut, plaintiffs in both suits pressed two arguments on appeal. First, they challenged the constitutionality of the statutes under the Second Amendment; and second, they challenged certain provisions of the statutes as unconstitutionally vague. Defendants in the New York action also cross-appealed the District Court's invalidation of New York's separate seven-round load limit and voiding of two statutory provisions as facially unconstitutionally vague.
Did the core prohibitions by New York and Connecticut of assault weapons and large-capacity magazines violate the Second Amendment?
The court held that the core provisions of the New York and Connecticut laws prohibiting possession of semiautomatic assault weapons and large-capacity magazines did not violate the Second Amendment where, assuming that the prohibited conduct fell under the Second Amendment and applying intermediate scrutiny, the provisions were substantially related to public safety and crime reduction. The court also found that specific prohibition on the non-semiautomatic Remington 7615, Conn. Gen. Stat. § 53-202a(1), fell within the scope of the Second Amendment and failed intermediate scrutiny. New York's seven-round load limit, N.Y. Penal Law § 265.37, did not survive intermediate scrutiny in the absence of requisite record evidence and a substantial relationship with important state safety interests. Finally, the court found that no challenged provision in either New York or Connecticut statute was unconstitutionally vague.