Second Amendment Analysis  ·  United States v. Hemani  ·  Bruen History & Tradition Test

Justice Jackson’s Dangerous Invitation: Why Scrapping Bruen’s History-and-Tradition Test Would Put Rights Back Under Government Control

Legal Disclaimer: NY Safe Inc. and Peter Ticali are not attorneys. This article is for general educational and Second Amendment commentary purposes only. It is not legal advice and does not create an attorney-client relationship. Firearm laws change frequently. Consult qualified legal counsel for guidance specific to your situation.

In This Article

1. The News Hook: What Happened in Hemani
2. What Bruen Actually Requires
3. Jackson’s Concurrence: A Constitutional Admonition
4. The Innocent-Until-Proven-Guilty Problem
5. “Lower Courts Are Struggling” Is Not Surrender
6. The King George Problem
7. When Rights Rise and Fall With Elections
8. Hemani Shows Why Bruen Works
9. The Second-Class Right Problem
10. Why This Matters in New York
11. “Public Safety” Without Constitutional Limits
12. A Better Way: Three Principles
13. Answering the Strongest Criticisms
14. What NY Safe Inc. Stands For
15. Conclusion
16. Frequently Asked Questions

Breaking  ·  June 18, 2026

The Supreme Court unanimously held in United States v. Hemani that the federal government could not prosecute Ali Danial Hemani under 18 U.S.C. §922(g)(3)—the federal statute barring unlawful users of controlled substances from possessing firearms—based solely on his admitted marijuana use. The government offered no individualized proof that Hemani was an addict, dangerous, impaired while armed, or that he had ever misused the firearm.

The judgment was 9–0. But the most consequential part of Hemani was not the result. It was Justice Ketanji Brown Jackson’s concurrence—a direct invitation to replace Bruen’s history-and-tradition test with the very balancing framework the Supreme Court expressly rejected in 2022.

Sources: United States v. Hemani, No. 24-1234 (S. Ct. June 18, 2026)  ·  Spokesman-Review / USA Today Coverage

The News Hook: A Supreme Court Justice Wants to Scrap the Test That Finally Made the Second Amendment Real

The easy headline writes itself: Supreme Court protects marijuana user’s gun rights. That headline will drive clicks. It will not tell you what actually happened inside the case—or what is at stake for every law-abiding gun owner in New York and across the country.

The case involved Ali Danial Hemani, who kept a firearm in his home and admitted to using marijuana roughly every other day. Federal authorities did not claim he was armed while intoxicated. They did not claim his marijuana use made him violent. They did not claim he threatened anyone. They did not claim he used the firearm in a crime. The government’s theory was broader and more dangerous: once a person falls into the category of an “unlawful user” of a controlled substance, the government may automatically strip that person of the right to possess a firearm. Period. No individualized showing required.

Agents also found cocaine in a parent’s closet, which Hemani claimed was his, but the Supreme Court emphasized that the federal charge did not involve cocaine possession, trafficking, terrorism, or firearm misuse; the prosecution rested on his admitted marijuana use and firearm possession at home.

The Supreme Court unanimously rejected that theory as applied to Hemani. Justice Neil Gorsuch’s majority opinion read the historical record carefully and found that the government’s analogues—laws involving habitual drunkards, public intoxication, vagrancy, and persons deemed dangerous—did not justify automatic disarmament of a person whose regular marijuana use, standing alone, had not been shown to create the kind of danger those historical laws addressed. That is exactly what New York State Rifle & Pistol Association v. Bruen requires. And that is exactly what Justice Jackson’s concurrence attacked.

The concurrence is important precisely because it says the quiet part out loud. Many opponents of Bruen do not merely want clarification. They want replacement. They want to return to a world where the government presents a safety rationale, and judges balance the right away. Justice Jackson made that ambition explicit. That is not a gun story. It is a constitutional-power story. And it demands a direct answer.

Is the Constitution a real limit on government power, or is it a flexible policy document courts may reshape whenever elected officials claim a modern emergency? Is the Second Amendment a right the government must respect unless it can prove a historically grounded basis for restricting it—or a privilege that survives only when judges decide the government’s stated safety interest is insufficiently persuasive? Those are the questions Hemani raises. They are worth answering carefully.

What Bruen Actually Requires

In New York State Rifle & Pistol Association v. Bruen (2022), the Supreme Court rejected the two-step framework many lower courts had used after District of Columbia v. Heller (2008). Under that older approach, courts asked first whether the Second Amendment was implicated, then applied means-end scrutiny—often intermediate scrutiny—asking whether the restriction was substantially related to an important governmental interest. In practice, that second step frequently swallowed the right entirely.

Bruen’s holding is straightforward: when the Second Amendment’s plain text covers a person’s conduct, the Constitution presumptively protects that conduct. The burden then shifts entirely to the government to show that its regulation is consistent with the Nation’s historical tradition of firearm regulation. Under means-end scrutiny, the government says: “We have a public safety concern, data, and experts.” Under Bruen, the government must say something categorically different: “This restriction is consistent with the historical scope of the right the American people actually adopted.” That difference is everything.

Bruen did not create a new test from thin air. It returned Second Amendment doctrine to the same methodology courts apply to other enumerated rights—anchoring interpretation in text and historical meaning rather than the government’s current policy preferences. New York’s own experience shows why this matters: the Court held in Bruen itself that New York’s “proper cause” carry regime was unconstitutional, ending a system in which ordinary citizens were denied carry licenses unless they demonstrated a special need distinguishable from the general public.

Justice Jackson’s Concurrence Deserves a Constitutional Admonition

Justice Jackson’s concurrence deserves more than polite disagreement. It deserves a constitutional admonition. That is not a personal attack. The issue is not her character, intelligence, or motives. The issue is the constitutional consequence of the legal standard she is urging the Court to revive.

She argues that means-end scrutiny is a more rational way to assess firearm regulations. She criticizes Bruen as unworkable. She says lower courts are struggling with historical questions and that courts are better equipped to examine government purpose, burden on the right, and whether the law is sufficiently tailored. That sounds reasonable only if we forget why the Constitution exists. The Constitution was not written to make government regulation easy. It was written to make government power limited.

The American Revolution was not fought so the people could replace the distant will of King George III with the domestic will of an administrative state. The founders did not create a written Constitution so future judges could ask, case by case, whether a right still seems useful compared to a government program. They created a written Constitution to bind government down, separate power, preserve liberty, and ensure that rights do not depend on the permission of those temporarily holding office.

The National Archives describes the Bill of Rights as spelling out Americans’ rights in relation to their government. Not rights granted by government. Not rights that exist only when government finds them efficient. Rights that precede and constrain government power. Justice Jackson’s proposed return to means-end scrutiny would move in the wrong constitutional direction—making rights depend less on what the people ratified and more on what the government can persuade judges to accept today.

Under Bruen, the constitutional question is: Does the government have constitutional authority to do this? Under means-end scrutiny, the question becomes: Does the government have a strong enough reason to do this? Those are not the same question. Every government that has ever violated liberty had reasons—public order, safety, emergency, security, necessity, fear of disorder. The Constitution exists because reasons are not enough. A free society does not begin with suspicion, forcing citizens to earn back their freedom. It begins with liberty, and demands that government justify every restriction.

By the Numbers

The Innocent-Until-Proven-Guilty Problem

The presumption of innocence in criminal trials—the government must prove guilt beyond a reasonable doubt—is not mechanically identical to every constitutional challenge. Any serious legal analysis should be honest about that distinction. But the deeper moral architecture of the presumption matters here in the Second Amendment context.

In a free society, the government does not begin with suspicion and force citizens to earn freedom back. It begins with liberty and must prove, through lawful process, why a particular person may be punished, restrained, or disarmed. Means-end scrutiny undermines that structure in Second Amendment cases by allowing the government to treat peaceable citizens as members of a risk category before individualized wrongdoing is proven. It lets the state say: “People in this group may be more dangerous. People in this group may impose social costs. Therefore, we may burden the entire group.” That is not how a free society treats constitutional rights.

The government should prosecute violent crime. It should enforce laws against carrying while impaired, threatening others, assault, straw purchasing, domestic violence, and armed crime. It should remove firearms from people convicted of disqualifying offenses through constitutionally adequate process. None of that is in dispute. The distinction that matters is this: that is different from treating a broad class of peaceable citizens as presumptively unworthy of a constitutional right because government believes the category creates risk.

Hemani exposed that distinction precisely. The government did not prove Hemani was dangerous. It did not prove his marijuana use made him violent. It did not prove he carried while impaired. It relied on category membership alone: unlawful user of a controlled substance. Under Bruen, that was not enough. Under means-end scrutiny, it might have been. That is the specific danger in Justice Jackson’s concurrence. It would move Second Amendment law back toward a model where broad public safety claims can override individualized liberty—putting the peaceful gun owner on the defensive for harms he did not commit and has no intention of committing.

“Lower Courts Are Struggling” Is Not an Argument for Constitutional Surrender

Justice Jackson’s most practical argument is that lower courts are struggling to apply Bruen. That claim is not without merit. Historical analysis can be difficult. Founding-era records can be incomplete. Reconstruction-era laws can be complicated. Analogical reasoning produces disagreement. Judges are lawyers, not professional historians. Litigants do not always present the best historical records. Some courts have applied Bruen too narrowly; others have tried to water it down. That is all true.

But none of that proves Bruen is wrong. It proves compliance is hard. And hard compliance is not a defect when constitutional rights are at stake. Courts struggle with the First Amendment. They struggle with the Fourth Amendment. They struggle with due process, equal protection, religious liberty, digital privacy, and compelled speech. We do not respond by saying: “This is difficult, so let us give government an easier path to regulate.”

When lower courts struggle, appellate courts correct them. The Supreme Court clarifies. Lawyers build better records. Judges learn the methodology. Standards mature. Compliance improves. That is how constitutional law works across every provision of the Bill of Rights. The answer to poor Bruen compliance is better Bruen compliance—not a retreat to the very framework Bruen expressly rejected.

Justice Jackson’s argument also risks rewarding lower-court resistance. If judges can generate enough confusion around a constitutional standard, and that confusion becomes the justification for abandoning the standard, then constitutional rights are vulnerable to judicial noncompliance. A right would survive only if lower courts find it easy to administer. A Supreme Court Justice should be the last person to suggest that constitutional limits are expendable because compliance is hard. The hard work is the oath.

The King George Problem: Why the Founders Feared Convenient Government

The American constitutional structure was born from distrust of concentrated power. The Declaration of Independence catalogued grievances against a king who acted as if power itself justified control. The American system that followed was built to prevent that from reappearing under a different name, a different flag, or a different bureaucracy.

The founders understood that tyranny can arise wherever government power becomes self-justifying. It can come from a king. It can come from Parliament. It can come from a legislature, an executive agency, or courts that defer too easily to the political branches. It can come from a temporary majority convinced its emergency is more important than someone else’s rights. That is why the Constitution is filled with friction.

Bicameralism is friction. Presentment is friction. Federalism is friction. Separation of powers is friction. Judicial review is friction. Enumerated rights are friction. The Fourth Amendment warrant requirement is friction. The First Amendment is friction. The Second Amendment is friction. None of that friction is an accident. None of it is administrative inconvenience that should be engineered away by clever judicial methodology.

Friction is not failure. Friction is the safeguard.

The history-and-tradition test is a form of judicial friction. It prevents courts from saying: “The government has a compelling modern goal, so the right must yield.” If the government wants to restrict a constitutional right, it must do the work. If the legislature wants to burden arms, it must operate within historically recognized limits. If prosecutors want to imprison someone for possessing a firearm, they must show more than category-based fear. Justice Jackson’s concurrence treats that friction as a problem. It is Bruen’s greatest virtue.

The government exists to secure the rights of the people. It does not own those rights. It does not rent them back to us election by election. It does not decide, administration by administration, which rights remain administratively useful. That is not anti-government. It is constitutional government. The Revolution was not fought so Americans could trade the will of King George for the will of whichever administrative majority controls the next election.

Means-End Scrutiny Lets Rights Rise and Fall With Elections

The greatest danger of means-end scrutiny is that it makes constitutional rights vulnerable to political fashion. Under a balancing framework, the weight of the government’s interest can change with the political climate. If elected officials declare gun violence a public health emergency, courts may give the government more deference. If a future administration declares civil disorder, misinformation, drug abuse, or domestic unrest the emergency of the moment, courts applying the same balancing logic may defer there too.

That is not a stable constitutional order. It is pendulum government. One administration balances away gun rights in the name of public safety. Another balances away protest rights in the name of public order. Another balances away privacy in the name of national security. Each side applauds when its preferred emergency wins—and objects only when the same logic is applied against its own liberties. The lesson never quite lands: once you invite courts to balance rights against government interests, you cannot control which rights get balanced away next.

History and tradition does not solve every problem. No judicial test does. But it anchors Second Amendment doctrine outside the immediate politics of the day. It asks what the right meant, how it was historically regulated, and what limits the people accepted when the right was adopted and later applied against the states through the Fourteenth Amendment.

That anchor is especially important in New York, where lawmakers have repeatedly responded to Supreme Court Second Amendment decisions by looking for the next regulatory workaround. After Bruen, New York enacted the Concealed Carry Improvement Act—expanding sensitive places, changing private-property carry rules, and adding new licensing burdens. The practical message was clear: even when the Supreme Court recognizes the right, the state will search for the next workaround. Without Bruen, the government converts the right into a balancing problem. With Bruen, the government must confront constitutional history. That is a much harder assignment. It is supposed to be.

Hemani Shows Why the Bruen Test Works

Hemani is not proof that Bruen failed. It is proof that Bruen worked. The government advanced a broad theory—that regular unlawful drug use, without more, automatically disarms a person under 18 U.S.C. §922(g)(3). It tried to defend that theory by pointing to historical laws involving intoxication, habitual drunkards, vagrants, and persons deemed dangerous. The Court did not accept the government’s labels at face value. It examined the actual historical analogues, looked at who those laws targeted, why they existed, and how they operated. That is precisely the constitutional analysis Bruen requires.

The result was careful, not reckless. The Court did not say drug use is irrelevant to firearm safety. It did not say addicts can never be disarmed. It did not say dangerous people must remain armed. It did not hold that the statute is facially unconstitutional. It said something narrower and more principled: the government’s automatic theory went too far on the record before the Court. That is constitutional boundary drawing. It is exactly what a rights-protective test should do.

Compare this to United States v. Rahimi (2024), where the Court unanimously upheld the federal statute disarming persons subject to domestic violence protective orders. In Rahimi, the Court found sufficient historical tradition for disarming people adjudicated as dangerous through a legal process—a category the historical record recognized. Hemani and Rahimi together show how the test actually works: individualized dangerousness, proven through process, justifies disarmament. Categorical status membership, without more, does not.

If a case like Hemani can be resolved by doing the historical work—and resolved correctly—why abandon the test? If the government’s analogues were too broad, why reward the government with a more forgiving framework? If the problem is that lower courts have been inconsistent, why treat inconsistency as proof that the right should be easier to restrict? The evidence points in exactly the opposite direction: the test is working. Give it time, better records, and faithful application. What it does not need is a concurrence inviting the Court to start over.

The Second Amendment Cannot Be Treated as a Second-Class Right

The Supreme Court has repeatedly warned that the Second Amendment is not a second-class right. Yet means-end scrutiny helped lower courts treat it that way for years. The test is worth applying across the Bill of Rights to see how quickly the argument collapses.

Would we allow the government to require citizens to show a “special need” before speaking on controversial political topics, because speech can cause unrest? Would we permit warrantless home searches in high-crime neighborhoods because the government has a compelling interest in finding illegal weapons? Would we allow blanket restrictions on religious services because public health officials believe gatherings create risk? Would we uphold categorical surveillance of legal activists because officials claim they might radicalize?

Sometimes government does have legitimate regulatory power. Rights have limits. But the burden must stay where the Constitution puts it: on the government. The Second Amendment should not be the one right where courts begin with the government’s fear and work backward to justify the restriction.

Responsible gun owners understand limits. We teach limits. We teach safety, storage, situational awareness, de-escalation, lawful use of force, and the responsibility that comes with carrying a firearm. But the existence of irresponsible people does not erase the constitutional rights of responsible people. A person who commits a violent crime should be prosecuted. A person who is adjudicated dangerous through due process should not possess firearms. But a peaceable citizen does not lose a constitutional right because the government says people in his statistical category might be risky. That is the line Bruen holds. That is the line Justice Jackson’s approach would erase.

Why This Matters in New York

For New Yorkers, this debate is not theoretical. New York has some of the most complex firearm laws in the country. Licensing is slow. Rules differ by county. New York City has its own additional licensing layers. Sensitive-location restrictions create compliance traps that can turn a law-abiding citizen into a criminal. Ammunition background checks create delays. Semi-automatic rifle rules, pistol license amendments, training mandates, renewal requirements, and constantly shifting interpretations make ordinary compliance difficult even for people trying their best.

If courts return to means-end scrutiny, New York can defend nearly any restriction by invoking public safety. It can argue that more paperwork improves accountability—that longer delays improve screening—that more sensitive-place designations reduce risk—that more training mandates prevent accidents—that more administrative discretion gives officials flexibility to protect communities. Some regulations may be constitutionally valid. Some may not. The point is not that every firearm law is unconstitutional. The point is that public safety labels should not end the constitutional analysis.

Under Bruen, New York must do more than announce a safety interest. It must show that the regulation fits within the constitutional tradition. That matters to every New Yorker navigating the carry process:

• The student completing a required New York 18-hour concealed carry course and wondering why the burden is so high
• The Nassau County or Suffolk County applicant who has done everything right and still waits months for a decision
• The Westchester County resident navigating judicial licensing structures without a clear timeline
• The traveling gun owner trying to understand what the FOPA safe-passage rules actually protect when driving through New York

These are not abstract people in a law school hypothetical. They are ordinary citizens trying to comply with the law while exercising a constitutional right. When courts water down the standard, those citizens pay the price. The standard is not just doctrine. It is protection.

The Dangerous Logic of “Public Safety” Without Constitutional Boundaries

Public safety is a real government interest. No serious person denies that. Gun violence is real. Domestic violence is real. Criminal misuse of firearms is real. Negligent handling is real. Responsible gun owners should never minimize those harms. But public safety cannot become a magic phrase that dissolves constitutional limits.

When courts defer too easily to government safety claims, the government has every incentive to define the problem broadly and the right narrowly. The “risk” becomes whatever the government says it is. The “evidence” becomes whatever studies the government prefers. The “tailoring” becomes whatever burden the court is willing to tolerate. That is not rights protection. That is managed liberty.

Bruen does not prevent government from regulating firearms. It prevents the government from regulating without constitutional grounding. It demands that modern firearm laws remain connected to the historical scope of the right. That connection matters because it keeps courts from becoming policy referees—deciding not whether the Constitution permits a law, but whether the law seems useful to the judges doing the balancing.

Justice Jackson’s concurrence blurs that boundary by inviting courts to return to evaluating Congress’s ends and means. That would give judges the power to decide how much liberty is too much liberty in light of modern government objectives. It would shift Second Amendment jurisprudence from constitutional constraint to policy supervision. That is precisely what Bruen was meant to stop. You do not experience constitutional doctrine. You experience incidents—a delayed license, a confiscated firearm, a criminal charge for a technical violation. The constitutional standard determines whether government must justify that experience to you, or whether you must justify yourself to the government.

A Better Way: Individualized Dangerousness, Due Process, and Real Enforcement

Rejecting means-end scrutiny does not mean rejecting public safety. It means demanding a constitutionally grounded public safety model built on three principles:

Answering the Strongest Criticisms of the History-and-Tradition Test

Criticism 1: “But American history is ugly.”

Some historical firearm restrictions were racist, class-based, anti-Catholic, anti-Native, or aimed at enslaved and formerly enslaved people. That concern deserves an honest answer. Historical analysis must never treat oppressive laws as legitimate constitutional traditions. The Fourteenth Amendment is part of the constitutional story—and the Bruen framework explicitly requires courts to consider Reconstruction-era history, not just 1791. Courts should refuse to use racist disarmament laws as analogues, because those laws are examples of what the Constitution, properly understood, rejects. Bad history is not an argument for no history. It is an argument for better history.

Criticism 2: “The founders could not imagine modern problems.”

True. And the First Amendment applies to the internet. The Fourth Amendment applies to cell phones. The Fifth Amendment applies to digital evidence. The Sixth Amendment applies to modern forensic methods. No court says speech rights vanish online because the founders wrote with quills. Bruen allows analogical reasoning—the government does not need to find an 18th-century statute involving the exact same modern device or behavior. It must show a relevantly similar tradition in how and why the regulation burdens the right. That is judging. If the government cannot find a relevant historical tradition for a sweeping modern restriction, perhaps the problem is not the test. Perhaps the problem is the restriction.

What NY Safe Inc. Stands For

NY Safe Inc. exists in the real world, not a theoretical one. We train ordinary citizens who want to comply with the law, handle firearms safely, understand their responsibilities, and avoid becoming a danger to themselves or others. That is the work. And it is exactly that real-world experience that grounds what we believe about constitutional standards.

We reject both extremes. We reject the idea that gun ownership is responsibility-free. A firearm is a serious tool. Carrying one requires maturity, restraint, judgment, training, legal understanding, and emotional control. We also reject the idea that government may treat responsible citizens as presumptive threats until they prove otherwise. That rejection is not contradiction. It is the same principle applied consistently: accountability flows to those who commit harmful acts, not to the millions who never do and never will.

That is why training and constitutional advocacy belong together at NY Safe. Good training reduces risk. Good law respects rights. Good enforcement targets misconduct. Good courts keep government inside constitutional boundaries. None of those goals conflict. They reinforce each other.

For readers navigating New York’s carry process: start with proper training. Our New York 18-hour concealed carry class is built around safe handling, legal responsibility, mindset, de-escalation, and the realities of carrying in New York. Our instructors understand both the constitutional framework and the practical compliance requirements you will face. That combination is not common. We think it matters.

Conclusion: The Constitution Is Not Supposed to Be Easy for Government to Evade

Justice Jackson’s concurrence in United States v. Hemani is important because it reveals the next major front in the Second Amendment fight. The question is no longer only whether the right exists—Heller answered that. The question is no longer only whether the right extends outside the home—Bruen answered that. The question now is whether courts will enforce the right using a standard that actually limits government, or whether they will return to a balancing test that lets government interest swallow constitutional protection.

Justice Jackson would move the Court back toward balancing. That move should be resisted. Not because history is easy—it is not. Not because every firearm regulation is unconstitutional—it is not. Not because public safety is unimportant—it is vitally important. But because constitutional rights are not supposed to depend on judicial convenience, legislative anxiety, or the policy preferences of whoever won the last election.

If lower courts struggle with history and tradition, the answer is not surrender. The answer is compliance. The answer is correction. The answer is better records, better judging, better advocacy, and a Supreme Court willing to enforce its own precedent.

Justice Jackson’s concurrence is dangerous because it invites the Court to turn away from that discipline. It invites judges to ask whether the government’s goals are good enough rather than whether the government has constitutional authority. It invites courts to treat peaceable citizens as risk categories. It invites rights to rise and fall with political conditions. Government works for the people. The people do not hold rights at the convenience of government. That is the principle Bruen protects. And that is why the history-and-tradition test must not be scrapped.

Final Quotable — Peter Ticali, NY Safe Inc.

“The history-and-tradition test is not a failed experiment. It is a constitutional speed bump placed in front of government power. Removing it would not modernize the Second Amendment. It would subordinate the Second Amendment to the very government it was written to restrain.”

Peter Ticali  |  Founder, NY Safe Inc.  |  nysafeinc.com

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Legal Disclaimer & Primary Sources

Legal Disclaimer: NY Safe Inc. and Peter Ticali are not attorneys. This article is for general educational and Second Amendment commentary purposes only. It is not legal advice and does not create an attorney-client relationship. Firearm laws change frequently and may be interpreted differently by courts, agencies, and licensing authorities. Consult qualified legal counsel for advice about your specific situation. If you or someone you know is in crisis, please contact the 988 Suicide & Crisis Lifeline by calling or texting 988.

Primary Sources & Further Reading: United States v. Hemani, No. 24-1234 (S. Ct. June 18, 2026)  · NYSRPA v. Bruen, 597 U.S. 1 (2022)  · District of Columbia v. Heller, 554 U.S. 570 (2008)  · United States v. Rahimi, 602 U.S. __ (2024)  · 18 U.S.C. §922 (Cornell LII)  · National Archives: Bill of Rights  · National Archives: Separation of Powers  · National Archives: Fourteenth Amendment  · Spokesman-Review / USA Today Coverage