SCOTUS Bruen Decision Bearing Fruit: San Francisco Approves a Concealed Carry Application

Constitutional Carry
AP Photo/Al Behrman

The San Francisco Sheriff’s Office has approved a concealed carry permit application months after the Supreme Court of the United States Bruen (2022) decision changed the concealed carry landscape.

Concealed carry permit approval is extremely rare in the San Francisco area. So rare, in fact, that people had quit applying because they were convinced they would never get a permit.

That low rate of approval, the San Francisco Chronicle noted, was due to California’s pre-Bruen posture, which dictated that concealed carry permit applicants show “good cause” for needing to carry a gun before being issued a permit.

Breitbart News reported that the Supreme Court’s June 23, 2022, Bruen decision struck down a similar requirement in New York, one which required concealed carry applicants to show proper cause before being issued a permit.

Within two weeks of the ruling, Breitbart News observed that California, Maryland, and New Jersey had all dropped enforcement of their arbitrary concealed carry permit issuance requirements. Because of this change, the Chronicle pointed out, the concealed carry permit application of Benjamin Zheng, an automobile shop worker, was approved on Friday.

Until now, the San Francisco jurisdiction rarely approved a permit, and when it did, those receiving it most likely had political ties.

For example, “In 1995, the city granted 13 concealed-carry permits, according to records obtained by the Chronicle. That list included three Superior Court judges, a retired U.S. Army general and several attorneys and investigators.”

Average citizens gave up on getting a permit and quit applying.

The result? “By 2014, fewer than 10 people had the permits in the city.”

Fast forward to 2023 — the Bruen decision has changed the process for concealed carry permit issuance.

AWR Hawkins is an award-winning Second Amendment columnist for Breitbart News and the writer/curator of Down Range with AWR Hawkins, a weekly newsletter focused on all things Second Amendment, also for Breitbart News. He is the political analyst for Armed American Radio and a Turning Point USA Ambassador. AWR Hawkins holds a PhD in Military History, with a focus on the Vietnam War (brown water navy), U.S. Navy since Inception, the Civil War, and Early Modern Europe. Follow him on Instagram: @awr_hawkins. You can sign up to get Down Range at Reach him directly at


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