Circuit Court: 2nd Amendment Protects Right ‘to Carry Firearms for Personal Self-Defense Beyond the Home’

A woman points a blank gun at the photographers camera at a weapons shop in Frankfurt, Germany, 08 January 2016. Retailers have noted a massive increase in sales of weapons which do not require a license in recent times. Photo: BORIS ROESSLER/dpa BORIS ROESSLER / DPA

This week, the U.S. Court of Appeals for the District of Columbia issued a majority opinion stating that the Second Amendment protects a right “to carry firearms for personal self-defense beyond the home.”

This opinion was handed down in Wrenn v. District of Columbia, a case wherein the D.C. Circuit ruled that the city’s “good-reason” requirement for concealed carry issuance is not constitutional. When the ruling was issued, Breitbart News reported that the court issued a permanent injunction, barring future use of the “good-reason” clause to limit concealed carry permit issuance.

The Wrenn ruling was welcomed with open arms by concealed carriers, as it came roughly a month after the Supreme Court of the United States (SCOTUS) refused to hear Peruta v. California. In Peruta, the U.S. Court of Appeals for the Ninth Circuit ruled that Americans have no right to carry a concealed handgun outside the home for self-defense.

Peruta’s majority opinion was written by Judge William Fletcher and said, “We hold that the Second Amendment does not preserve or protect a right of a member of the general public to carry concealed firearms in public.” And contrary to what the D.C. Circuit ruled this week, the Peruta ruling upheld California’s “good cause” for concealed carry permit issuance.

So we have two views, diametrically opposed, on two separate coasts. On the east coast, the D.C. Circuit defended the right “to carry firearms for personal self-defense beyond the home,” and on the west coast, the Ninth Circuit ruled that no such right exists.

As this split festers, we may end up getting the SCOTUS review that Justice Clarence Thomas has been urging his colleagues to undertake. He called it “indefensible” when they refused to hear Peruta, and if D.C. appeals the D.C. Circuit decision, his colleagues will get the opportunity to review a similar case — Wrenn — in the shadow of an obvious circuit split.

Thomas is already on record saying SCOTUS ought not “sit idly by” as state-level gun control cripples the Second Amendment.

AWR Hawkins is the Second Amendment columnist for Breitbart News and host of Bullets with AWR Hawkins, a Breitbart News podcast. He is also the political analyst for Armed American Radio. Follow him on Twitter: @AWRHawkins. Reach him directly at


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