October 7, 2025 – In a major Second Amendment decision in Firearms Policy Coalition Inc. v. Bondi, the U.S. District Court for the Northern District of Texas ruled that federal laws prohibiting the possession and carrying of firearms in ordinary United States Post Offices are unconstitutional. On September 30, 2025, Judge O’Connor granted plaintiffs’ motion for summary judgment, declaring that 18 U.S.C. § 930(a) and 39 C.F.R. § 232.1(1) are unconstitutional under the Second Amendment with respect to Plaintiffs’ (and their members’) possession and carrying of firearms inside an ordinary post office and the surrounding postal property. This includes post offices that are not located on a military base or in federally owned or leased buildings housing government functions other than a post office, in which carrying a firearm would otherwise be prohibited. The court enjoined the Government from enforcing 18 U.S.C. § 930(a) and 39 C.F.R. § 232.1(1) (against plaintiffs and their members only) in accordance with its declaration.
18 U.S.C. § 930(a) states that “whoever knowingly possesses or causes to be present a firearm or other dangerous weapon in a Federal facility (other than a Federal court facility), or attempts to do so, shall be fined under this title or imprisoned not more than 1 year, or both.” 18 U.S.C. § 930(g) defines a “Federal facility” as any “building or part thereof owned or leased by the Federal Government, where Federal employees are regularly present for the purpose of performing their official duties.” 39 C.F.R. § 232.1(l), enacted by the United States Postal Service on November 16,1972, states that “[n]otwithstanding the provisions of any other law, rule or regulation, no person while on postal property may carry firearms, other dangerous or deadly weapons, or explosives, either openly or concealed, or store the same on postal property, except for official purposes.” A violation of this regulation is subject to criminal penalties, including a fine, imprisonment for a term not exceeding 30 days, or both, pursuant to 39 C.F.R. § 232.1(p)(2).
Interpreting the Supreme Court’s decision in N.Y. State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), the court determined that because the possession of a firearm for self-defense within a post office or on postal property falls within the plain text of the Second Amendment, the Government bore the burden of demonstrating that the prohibition of firearms in such locations is consistent with the Nation’s historical tradition of firearm regulation. The Government argued that post offices qualify as “sensitive places,” comparable to legislative assemblies, polling places, and courthouses, venues historically recognized as central to governmental functions and potentially susceptible to disruption by the presence of firearms. The court rejected this argument, finding no historical analogue supporting a blanket ban on firearms within a post office or on postal property. The court held that firearms restrictions affecting government property are subject to the same historical inquiry as other firearm regulations, rather than a carveout as the Government argued. While this decision only applies to the plaintiffs and their members (Firearms Policy Coalition and Second Amendment Foundation), if upheld on appeal, it could have broader effects.
In related news, the U.S. Supreme Court has agreed to hear another Second Amendment case this term. The Court granted certiorari in Carralero v. Bonta to review a Ninth Circuit decision holding that a California law prohibiting individuals from carrying firearms on private property unless they have express permission to do so is constitutional. The Second Circuit recently found a similar law in New York to be in violation of the Second Amendment. These laws were enacted by several states in response to the Supreme Court’s Bruen decision. Because the Supreme Court found that restricting the permitting process to carry of firearm on a discretionary basis was unlawful, these states decided instead to try to heavily restrict where any permit holders could legally carry. As such, carrying on private property was deemed illegal by default, and only allowed if the owner expressly gave permission to do so. A decision in the Carralero case is expected by next summer.
Renzulli Law Firm will continue to monitor these lawsuits and related litigation challenging the constitutionality of gun control laws. If you have any questions about laws regulating firearms and ammunition, please contact John F. Renzulli or Christopher Renzulli.