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Second Amendment Foundation just picked up another major courtroom win against New York’s post-Bruen carry restrictions. And one of the state’s most controversial anti-carry rules is officially staying down.
In a new ruling tied to Christian v. James, the United States Court of Appeals for the Second Circuit affirmed a lower court injunction blocking New York’s so-called “Vampire Rule,” which effectively banned lawful concealed carry on nearly all private property open to the public unless owners posted explicit permission signs.
In other words, the default was “no carry” almost everywhere.
Gun rights groups argued the law was an obvious workaround to the Supreme Court’s landmark New York State Rifle & Pistol Association v. Bruen ruling after New York was forced to start issuing carry permits under constitutional standards.
And the court appears to have agreed.
“New York’s carry ban on private property open to the public – essentially all private businesses – was intended as the state’s next novel circumvention of the Second Amendment,” said SAF Senior Director of Legal Operations Bill Sack. “We are thrilled the Second Circuit saw through this ruse and tossed the ban out on its rear end.”
The lawsuit was brought by SAF alongside Firearms Policy Coalition and plaintiff Brett Christian. But the ruling wasn’t a total sweep.
The court also upheld New York’s ban on carrying firearms in parks, rejecting SAF’s arguments that the restriction also violates the Second Amendment. According to SAF, at least one judge issued a notable dissent on that portion of the opinion.
That means the fight over what counts as a legitimate “sensitive place” is far from over.
Since Bruen dropped in 2022, anti-gun states like New York, California, New Jersey, and others have tried to redraw massive portions of public life into gun-free zones, often using broad “sensitive places” language to restrict where permit holders can legally carry.
Critics say the strategy was never about safety as much as making carry permits functionally useless.
SAF founder Alan Gottlieb made it clear the organization isn’t done pushing back.
“The ideologues who think they can create ‘sensitive places’ to ban the legal carry of firearms should understand that SAF will continue to fight for the right to keep and bear arms for all Americans,” Gottlieb said.
For New York gun owners, today’s ruling means one thing is now crystal clear: the state can’t simply wave a wand and declare almost every privately-owned business off limits to lawful carry holders.
At least not without a fight.
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is a seasoned outdoorsman, lifelong hunter, and the kind of guy who’d rather track whitetails than scroll social media. As an editor for GunsAmerica, he’s got a sharp eye for spotting both solid gear and bad gun laws. Whether he’s deep in the woods or deep in editorial deadlines, Larry brings a no-nonsense, tell-it-like-it-is approach to firearms, hunting, and the great American tradition of self-reliance. If there’s a hot debate on gun rights or the latest in hunting tech, you can bet Larry’s got an opinion—and it’s probably backed up with both facts and field experience.
Experience:
– Licensed Bowhunter, Hunter, and Trapper – Experienced in ethical hunting and wildlife conservation.
– Concealed Carry Permit Holder (NYS & AZ) – Trained and licensed to carry in multiple states.
– 2A Journalist – Covering firearms legislation, Second Amendment issues, and gun rights for over a decade.
– Emergency Medical Technician (EMT) – Certified to provide emergency medical care in the field.
– Field-Tested Gear Reviewer – Hands-on experience with firearms, optics, and hunting tech.
