In 2025, the National Rifle Association worked just as hard battling to protect the Second Amendment in the courts as we did in Congress and state legislatures, so we wanted to make sure you knew what was going on.
We defeated New Mexico’s seven-day waiting period for firearm purchases, the ATF’s “engaged in the business” rule, the ATF’s “pistol-brace” rule, a lawsuit seeking to ban lead ammunition in the Canaan Valley National Wildlife Refuge and, in a case now being reheard by the en banc Ninth Circuit, California’s background-check requirement for ammunition purchases. NRA filed 10 new cases; three petitions for certiorari in the U.S. Supreme Court; and 20 amicus briefs, including nine in the U.S. Supreme Court. NRA counsel also published three law review articles, hosted webinars to discuss our litigation efforts across the country and continued its Legal Scholar Video Series, all while litigating dozens of other cases across the country.
Litigation Victories
• Ortega v. Grisham: The Tenth Circuit Court of Appeals held that New Mexico’s seven-day waiting period for firearm purchases violates the Second Amendment in August 2025. The state petitioned for rehearing en banc, but the court denied that petition last week.
• Butler v. ATF: In October 2025, an Alabama federal district court held that the ATF exceeded its statutory authority by issuing its 2024 Final Rule expanding the definition of what counts as being “engaged in the business” of “dealing in firearms.” The court permanently enjoined the ATF and the DOJ from enforcing several of the Final Rule’s provisions against NRA members.
• Rhode v. Bonta: The Ninth Circuit Court of Appeals struck down California’s background-check requirement for ammunition purchases in July 2025. But the court voted to rehear the case en banc in December 2025. En banc oral argument has been scheduled for the week of March 23, 2026.
• NRA v. ATF & FRAC v. ATF: After defeating the ATF’s “pistol brace” rule in the Eighth Circuit Court of Appeals in FRAC v. ATF, the ATF conceded that its rule was unenforceable and these two challenges were resolved.
• National Wildlife Refuge Association v. Haaland: The plaintiffs dismissed their lawsuit—in which the NRA intervened—that aimed to ban lead ammunition in the Canaan Valley National Wildlife Refuge.
New Cases
• Brown v. ATF: A challenge to the National Firearms Act of 1934’s restrictions on suppressors, short-barreled long guns and NFA-defined “any other weapons,” filed in Missouri.
• Jensen v. ATF: An NRA-supported challenge to the National Firearms Act of 1934’s restrictions on suppressors, short-barreled long guns and NFA-defined “any other weapons,” filed in Texas.
• Hanlon v. Campbell: A challenge to Massachusetts’ ban on “assault-style firearms.”
• Escher v. Noble: A challenge to Massachusetts’ law prohibiting adults under 21 from possessing or carrying any handgun or semi-automatic firearm.
• Jaymes v. Bonta: A challenge to California’s ban on Glock-style handguns.
• Padua v. Platkin: A challenge to New Jersey’s ban on suppressors.
• Struck v. Platkin: A challenge to New Jersey’s “one-gun-a-month” restriction.
• Dunn v. Glass: A challenge to Florida’s three-day waiting period requirement for firearm purchases.
• Langston v. Humphreys: A challenge to Colorado’s excise tax on firearm and ammunition sales.
• Sportsmen’s Alliance Foundation v. BLM: A challenge to the Bureau of Land Management’s shooting ban on the Sonoran Desert National Monument.
Cert Petitions
• NRA v. Glass: NRA petitioned the Supreme Court to hear its challenge to Florida’s ban on firearm purchases by adults under 21. Florida responded to the petition by urging the Court to hear the case and rule its own law unconstitutional. The Court distributed the petition for the Nov. 14, 2025, conference, and has not yet ruled on it.
• Duncan v. Bonta: A petition for certiorari was filed urging the Supreme Court to hear this NRA-supported challenge to California’s prohibition and confiscation of magazines that hold over 10 rounds. The Court first distributed the petition for the Dec. 5, 2025, conference, and then redistributed it for the Dec. 12, 2025, conference, and has not yet ruled on it.
• Rush v. United States: NRA-ILA counsel petitioned the Supreme Court to hear a challenge to the National Firearms Act of 1934’s tax and registration requirements for short-barreled rifles. The Court denied the petition on Dec. 15, 2025.
These are just highlights of a busy and productive year fighting for your rights in the courts. Many earlier cases continue to make their way through the legal process, and NRA-ILA is also engaged in the process of legal scholarship and continuing education for legal professionals. Please stay tuned to nraila.org for future updates on NRA-ILA’s ongoing efforts to defend your constitutional rights, and please visit nraila.org/litigation to keep up to date on NRA-ILA’s ongoing litigation efforts.
