1st Circuit Court Rules on Massachusetts Assault Weapons Ban
April 21, 2025, 2:17 pm CDT
The Massachusetts law banning assault weapons and large-capacity ammunition magazines has been upheld by the 1st U.S. Circuit Court of Appeals, providing clarity on the constitutionality of firearm regulations.
In a significant ruling on April 17, 2025, the 1st Circuit Court in Boston indicated that the state’s prohibition of assault weapons, including popular firearms like the Colt AR-15, is likely constitutional and in alignment with historical firearms regulations. This decision emerges from a challenge posed by Massachusetts resident Joseph R. Capen and the National Association for Gun Rights, who sought to contest the legality of the law.
Constitutional Framework
The appeals court based its ruling on the framework set forth by the U.S. Supreme Court in the 2022 case New York State Rifle & Pistol Association Inc. v. Bruen, which established that regulations around firearms must adhere to the historical traditions of firearm control in the United States.
In affirming the lower court’s denial of a preliminary injunction against the ban, the 1st Circuit emphasized that the plaintiffs did not provide evidence showing that banned firearms, such as the AR-15, have been utilized in self-defense situations. The court noted, “For one thing, the challengers do not demonstrate a single instance where the AR-15—or any other banned weapon—has actually been used in a self-defense scenario.”
Historical Context
The judges pointed out that the Massachusetts statute aligns with historical precedents where specific weapons were banned once their potential danger to public safety was evident. Noteworthy examples include prior regulations on trap guns, long-bladed knives, blunt instruments, sawed-off shotguns, and machine guns, suggesting a historical consistency with the current stance on assault weapons.
The court affirmed that the restrictions imposed by the Massachusetts law do not create an unusual hindrance to citizens’ rights to self-defense. Moreover, in reference to the prohibition on high-capacity magazines, the appeals court connected this ruling with its earlier 2024 decision regarding Rhode Island’s similar ban, indicating its likely constitutionality.
The opinion was authored by Judge Gary Katzmann, who was appointed to sit temporarily on the 1st Circuit panel for this case, Capen v. Campbell.
For media coverage of this landmark decision, outlets such as Bloomberg Law and Reuters have provided extensive reporting.
