Fahr
Fahr v. City of San Diego, California
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 10 JAMES FAHR, et al., Case No. 21-cv-1676-BAS-BGS
Plaintiffs,
ORDER DIRECTING PARTIES TO
v. PROVIDE SUPPLEMENTAL
BRIEFING
CITY OF SAN DIEGO, et al.,
Defendants. 16 In the wake of the United States Supreme Court’s decision in District of Columbia v. Heller, 544 U.S. 570 (2008) (“Heller”), the Courts of Appeals each devised a two-step constitutional framework for assessing Second Amendment challenges, bearing similarity across the eleven Circuits. See, e.g., Young v. Hawaii, 992 F.3d 765, 782 (9th Cir. 2021).1 In the Ninth Circuit, for example, courts first examine whether the “challenged law affects conduct that is protected by the Second Amendment” based upon a “historical 23 1 Each of the other ten United States Courts of Appeals have adopted similar two-step analytical 24 approaches to the Second Amendment as the Ninth Circuit. See Worman v. Healey, 922 F.3d 26, 33, 36– 39 (1st Cir. 2019);…