BELLEVUE, Wash. — Nov. 21, 2025 — The Second Amendment Foundation (SAF) has filed an amicus brief with the U.S. Supreme Court in Wolford v. Lopez, urging the Court to reverse the Ninth Circuit’s decision upholding Hawaii’s infamous “Vampire Rule.”
The Hawaii law, like similar statutes in California, New York and other states, declares virtually all private property open to the public — grocery stores, gas stations, restaurants and more — off-limits for lawful carry unless the property owner gives express permission. The result: permit holders who wish to exercise their Second Amendment rights are effectively banished from most places.
“This is the post-Bruen rebellion in its purest form,” said SAF Director of Legal Research and Education Kostas Moros. “Anti-gun states invented the ‘Vampire Rule’ for the sole purpose of nullifying the right to carry. They are not protecting private property rights – they are deliberately making public carry so burdensome that citizens will simply give up. The Ninth Circuit blessed this transparent end-run around the Second Amendment and only the Supreme Court can stop it.”
SAF is joined in the amicus by the Citizens Committee for the Right to Keep and Bear Arms, Connecticut Citizens Defense League and Minnesota Gun Owners Caucus.
“If the Ninth Circuit’s decision stands, the constitutional right to bear arms in public for self-defense will exist only on paper in large parts of the country,” said SAF founder and Executive Vice President Alan M. Gottlieb. “The Supreme Court made clear in Bruen that the right to carry cannot be eviscerated by turning nearly every place people actually go into a gun-free zone. We are confident the Justices will take this case and put an end to this ‘Vampire Rule’ once and for all.”
For more information visit SAF.org.
The Second Amendment Foundation (saf.org) is the nation’s oldest and largest tax-exempt education, research, publishing and legal action group dedicated to safeguarding and promoting the fundamental rights of individuals enshrined in the Second Amendment of the United States Constitution. SAF engages in aggressive legal action to ensure the principles of armed self-defense, personal liberty, and the ownership of arms are defended, secured, and restored. Through public education initiatives, SAF teaches the importance of the Second Amendment to promote a society that values and exercises the right to keep and bear arms.
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