A new federal lawsuit filed in the U.S. District Court for the District of Hawaii is challenging the state’s policy of refusing to issue concealed carry permits to non-residents, arguing the restriction violates the Second and Fourteenth Amendments.
The case, Solinsky v. Lopez, was filed on March 7, 2026, by Johnathan Solinsky and the Hawaii Rifle Association (HRA). The lawsuit names Hawaii Attorney General Anne E. Lopez as the defendant in her official capacity and seeks declaratory and injunctive relief against Hawaii’s residency requirement for concealed carry licenses.
At issue is Hawaii Revised Statutes §134-9(a), which requires an applicant for a concealed carry permit to be “a resident of the State.” The plaintiffs argue that requirement effectively bars visitors from legally carrying firearms for self-defense while in Hawaii.
According to the complaint, Solinsky is a Virginia resident, U.S. Marine Corps veteran, and firearms instructor who frequently travels to Hawaii. On September 5, 2025, he applied for a concealed carry permit through the Honolulu Police Department.
The application was ultimately denied on February 3, 2026, solely because Solinsky is not a resident of Hawaii.
The complaint states that Solinsky otherwise met the requirements necessary to obtain a permit, but Hawaii law prohibits issuing carry licenses to individuals who do not reside in the state.
Because Hawaii requires a license to carry a handgun in public, the plaintiffs argue that the residency requirement effectively prevents law-abiding visitors from exercising the right to bear arms for self-defense while traveling in the state.
The lawsuit relies heavily on the U.S. Supreme Court’s 2022 decision in New York State Rifle & Pistol Association v. Bruen, which held that firearm regulations must be consistent with the nation’s historical tradition of gun regulation.
Under the Bruen framework, courts must determine whether a modern gun law is supported by comparable historical restrictions dating to the Founding era or Reconstruction.
The complaint argues Hawaii’s residency requirement fails that test.
According to the filing, historical regulations often recognized the right of travelers to carry arms while moving between jurisdictions. The plaintiffs cite several historical statutes that included exceptions for travelers, including early laws from Kentucky and Indiana that allowed travelers to carry weapons despite restrictions that applied to residents.
The lawsuit contends these historical examples show that American law traditionally protected the right of individuals to bear arms while traveling rather than restricting it based on residency.
The Hawaii Rifle Association, a nonprofit organization that advocates for Second Amendment rights in the state, joined the lawsuit as a co-plaintiff.
The organization states that some of its members live outside Hawaii but regularly travel to the islands and would seek permits if the state allowed non-residents to apply. The complaint argues that Hawaii’s law prevents those members from exercising their right to bear arms while visiting the state.
The plaintiffs are asking the federal court to:
- Declare Hawaii’s residency requirement for concealed carry permits unconstitutional
- Issue an injunction blocking enforcement of the restriction
- Allow qualified non-residents to apply for concealed carry permits in Hawaii
If the court ultimately agrees with the plaintiffs, Hawaii could be forced to change its permitting system to allow non-resident applications.
Residency restrictions on firearm carry permits have become a growing point of litigation across the country following the Supreme Court’s decision in Bruen. Courts are increasingly examining whether states may restrict the right to bear arms based on where a person lives.
The outcome of Solinsky v. Lopez could therefore have implications beyond Hawaii, particularly for travelers who wish to carry firearms for self-defense while visiting other states.
For now, the case begins its path through the federal courts as plaintiffs ask a judge to apply the Bruen standard to Hawaii’s residency requirement and determine whether the state can continue to deny carry permits to non-residents.
Wolford v. Lopez: Why the Supreme Court’s Latest 2nd Amendment Case Risks Missing the Real Threat
