Narrow holdings with broad consequences

June brought two Second Amendment decisions. In United States v. Hemani, the court unanimously sustained Ali Hemani’s challenge to his indictment under 18 U.S.C. § 922(g)(3), for possessing firearms while being an unlawful user of a controlled substance. And in Wolford v. Lopez, the court held unconstitutional a Hawaii law that requires concealed-carry permit holders to obtain property owners’ express permission before carrying a firearm onto private property held open to the public.These outcomes did not come as much of a surprise after oral arguments, and both decisions are framed, properly, as narrow answers to the specific questions before the Supreme Court. Section 922(g)(3) remains on the books, and we have little in the way of express guidance on the “sensitive place” legislation on which states have largely relied to restrict carriage of firearms in locations such as parks and public transportation.Still, these are important decisions, and they provide unmistakable guidance that ought to lead to sounder adjudication of Second Amendment claims in the lower courts. Here are three important take-aways.I.   Bruen is here to stay.In 2022, the Supreme Court reset Second Amendment litigation by announcing a new test for adjudicating such challenges. To begin, the person challenging the law must show that the conduct it regulates or prohibits falls within the plain text of the amendment. Then, the burden shifts to the government to show that the law is consistent wi