The most significant Second Amendment case to come out of New York in spring 2025 was Antonyuk v. James, a direct challenge to the state’s Concealed Carry Improvement Act (CCIA). On April 7, 2025, the United States Supreme Court declined to hear the case, leaving in place a decision by the Second Circuit Court of Appeals that largely upheld New York’s post-Bruen gun law. The Court’s refusal to intervene was a major victory for state officials and a pivotal moment in the ongoing national debate over firearms regulation.
Background: The Bruen Decision and New York’s Response
In June 2022, the Supreme Court issued its landmark decision in New York State Rifle & Pistol Association v. Bruen. That ruling struck down New York’s longstanding requirement that applicants for concealed carry permits show “proper cause” to justify their need to carry a firearm. The Court held that the Second Amendment protects the right of ordinary citizens to carry firearms in public for self-defense, and that New York’s discretionary licensing scheme was unconstitutional.
In response, New York lawmakers enacted the Concealed Carry Improvement Act (CCIA). The law sought to impose new restrictions and standards on gun ownership, including:
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A ban on carrying firearms in so-called “sensitive locations” such as schools, government buildings, houses of worship, and public transportation.
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A requirement that applicants demonstrate “good moral character” when applying for a handgun license.
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New obligations for applicants to disclose past and present social media accounts.
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A presumption that carrying a firearm on private property was unlawful unless the property owner expressly allowed it.
Gun rights advocates quickly challenged these provisions, leading to Antonyuk v. James.
The Second Circuit’s 2024 Ruling
In October 2024, the Second Circuit Court of Appeals issued a significant ruling. The court upheld most of the CCIA, including the “sensitive locations” provision and the “good moral character” requirement. Both were seen as central to the state’s effort to regulate firearms after Bruen.
However, the Second Circuit struck down two parts of the law:
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Social Media Disclosure Requirement – The court ruled that requiring applicants to submit their social media accounts was overly broad and violated constitutional protections.
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Private Property Presumption – The provision making firearm possession presumptively unlawful on private property without express consent was also struck down, with the court reasoning that it improperly burdened lawful carry rights.
The Supreme Court Declines Review
On April 7, 2025, the Supreme Court denied certiorari in Antonyuk v. James. By refusing to take up the case, the Court allowed the Second Circuit’s decision to remain the controlling law in New York. This means that, as of now, most of the CCIA—including the sensitive locations ban and good moral character requirement—remains in full effect.
The decision was seen as a major win for New York officials, who argued that the CCIA was a constitutional and necessary response to Bruen. Gun rights advocates, by contrast, expressed disappointment, noting that the Court missed an opportunity to further define the scope of the Second Amendment in the wake of its 2022 ruling.
What This Means Going Forward
The Supreme Court’s inaction signals that states retain significant leeway to regulate firearms, even after Bruen. While outright bans or highly discretionary licensing schemes may not survive judicial scrutiny, laws focused on sensitive locations, character requirements, and other regulatory measures may still stand.
For New York gun owners and applicants, the practical effect is clear: most of the CCIA remains enforceable law. Those applying for handgun licenses should expect to meet the good moral character requirement, and restrictions on carrying in sensitive places continue to apply. At the same time, the removal of the social media disclosure and private property presumptions demonstrates that courts are willing to strike down overreaching provisions.
As the national debate over gun rights continues, Antonyuk v. James stands as an important reminder that the contours of the Second Amendment are still being shaped—and New York remains at the center of that evolving legal landscape.