George Young, Jr. v. State of Hawaii

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT GEORGE K. YOUNG, JR., No. 12-17808 Plaintiff-Appellant, D.C. No. v. 1:12-cv-00336- HG-BMK STATE OF HAWAII; NEIL ABERCROMBIE, in his capacity as Governor of the State of Hawaii; OPINION DAVID MARK LOUIE I, Esquire, in his capacity as State Attorney General; COUNTY OF HAWAII, as a sub-agency of the State of Hawaii; WILLIAM P. KENOI, in his capacity as Mayor of the County of Hawaii; HILO COUNTY POLICE DEPARTMENT, as a sub-agency of the County of Hawaii; HARRY S. KUBOJIRI, in his capacity as Chief of Police; JOHN DOES, 1–25; JANE DOES, 1–25; DOE CORPORATIONS, 1–5; DOE ENTITIES, 1–5, Defendants-Appellees. 2 YOUNG V. STATE OF HAWAII Appeal from the United States District Court for the District of Hawaii Helen W. Gillmor, District Judge, Presiding Argued and Submitted En Banc September 24, 2020 San Francisco, California Filed March 24, 2021 Before: Sidney R. Thomas, Chief Judge, and Diarmuid F. O’Scannlain, M. Margaret McKeown, Kim McLane Wardlaw, William A. Fletcher, Richard R. Clifton, Jay S. Bybee, Consuelo M. Callahan, Sandra S. Ikuta, Michelle T. Friedland and Ryan D. Nelson, Circuit Judges. Opinion by Judge Bybee; Dissent by Judge O’Scannlain; Dissent by Judge R. Nelson YOUNG V. STATE OF HAWAII 3 SUMMARY* Civil Rights The en banc court affirmed the district court’s dismissal of an action challenging Hawai‘i’s firearm licensing law, Hawai‘i Revised Statutes § 134-9(a), which requires that residents seeking a license to openly carry a firearm in public must demonstrate “the urgency or the need” to carry a firearm, must be of good moral character, and must be “engaged in the protection of life and property.” Appellant George Young applied for a firearm-carry license twice in 2011, but failed to identify “the urgency or the need” to openly carry a firearm in public. Instead, Young relied upon his general desire to carry a firearm for self- defense. Both of Young’s applications were denied. Young brought a challenge to Hawai‘i’s firearm-licensing law under the Second Amendment and the Due Process Clause of the Fourteenth Amendment. The district court upheld Hawai‘i’s statute. The en banc court first held that the scope of its review would be limited to Young’s facial challenge to HRS § 134-9. There was no need to determine whether Hawai‘i County properly applied § 134-9, because Young did not bring an as- applied challenge. The en banc court noted that this Court has previously held that individuals do not have a Second Amendment right * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader. 4 YOUNG V. STATE OF HAWAII to carry concealed weapons in public. Peruta v. County of San Diego, 824 F.3d 919 (9th Cir. 2016) (en banc). The question presented in this case, accordingly, was limited to whether individuals have a right to carry weapons openly in public. To answer that question, and consistent with the Supreme Court’s decisions in District of Columbia v. Heller, 554 U.S. 570 (2008), and McDonald v. City of Chicago, 561 U.S. 742 (2010), the en banc court first considered whether Hawai‘i’s law affects conduct protected by the Second Amendment. After careful review of the history of early English and American regulation of carrying arms openly in the public square, the en banc court concluded that Hawai‘i’s restrictions on the open carrying of firearms reflect longstanding prohibitions, and therefore, the conduct they regulate is outside the historical scope of the Second Amendment. The en banc court held that the Second Amendment does not guarantee an unfettered, general right to openly carry arms in public for individual self-defense. Accordingly, Hawai‘i’s firearms-carry scheme is lawful. The en banc court rejected Young’s argument that HRS § 134-9 is invalid as a prior restraint because it vests chiefs of police with unbridled discretion to determine whether a permit is issued. Joining its sister circuits, the en banc court held that the prior restraint doctrine does not apply to Second Amendment challenges to firearm-licensing laws. The en banc court also rejected, as premature, Young’s due process argument that HRS § 134-9 does not provide adequate process to challenge the denial of a carry-permit application. The en banc court noted that Young did not seek review under HRS § 91-9 before bringing suit. So, YOUNG V. STATE OF HAWAII 5 Hawai‘i has not yet denied him the opportunity for appellate review. Because Young has not actually been denied a hearing, his procedural due process claim was speculative, and there was no need to reach it. Dissenting, Judge O’Scannlain, joined by Judges Callahan, Ikuta, and R. Nelson, would hold that both HRS § 134-9 and the 1997 County regulation destroy the core right to carry a gun for self-defense outside the home and are unconstitutional under any level of scrutiny. Judge O’Scannlain stated that the majority holds that while the Second Amendment may guarantee the right to keep a firearm for self-defense within one’s home, it provides no right whatsoever to bear—i.e., to carry—that same firearm for self-defense in any other place. In his view, the majority’s decision undermines not only the Constitution’s text, but also half a millennium of Anglo-American legal history, the Supreme Court’s decisions in District of Columbia v. Heller, 554 U.S. 570 (2008), and McDonald v. City of Chicago, 561 U.S. 742 (2010), and the foundational principles of American popular sovereignty itself. Dissenting, Judge R. Nelson, joined by Judges Callahan and Ikuta, concurred with Judge O’Scannlain’s dissent concluding that Hawaii Revised Statute 134-9 violates the Second Amendment. Judge R. Nelson wrote that the majority erred not only in holding the statute facially constitutional, but also in rejecting Young’s as-applied challenge. He also wrote separately to highlight the brazenly unconstitutional County of Hawaii Regulations applying HRS § 134-9, stating that there should be no dispute that any law or regulation that restricts gun ownership only to security guards violates the Second Amendment. 6 YOUNG V. STATE OF HAWAII COUNSEL Alan Alexander Beck (argued), San Diego, California; Stephen D. Stamboulieh, Stamboulieh Law PLLC, Madison, Mississippi; for Plaintiff-Appellant. Neal Kumar Katyal (argued), Colleen E. Roh Sinzdak, Mitchell P. Reich, and Sundeer Iyer, Hogan Lovells US LLP, Washington, D.C.; Clare E. Connors, Attorney General; Kimberly T. Guidry, Solicitor General; Robert T. Nakatsuji and Kaliko‘Onalani D. Fernandes, Deputy Solicitors General; Department of the Attorney General, Honolulu, Hawaii; Joseph K. Kamelamela, Corporation Counsel; Laureen L. Martin, Litigation Section Supervisor; D. Kaena Horowitz, Melody Parker, Christopher P. Schlueter, Michael J. Udovic, and Kimberly K. Angay, Deputies Corporation Counsel; Office of the Corporation Counsel, Hilo Hawaii; for Defendants-Appellees. Kimberly T. Guidry, Solicitor General; Robert T. Nakatsuji, Deputy Solicitor General; Department of the Attorney General, Honolulu, Hawaii; for Amicus Curiae State of Hawaii. Deepak Gupta and Jonathan E. Taylor, Gupta Wessler PLLC, Washington, D.C.; Eric Tirschwell and Mark Anthony Frassetto, Everytown for Gun Safety Support Fund, New York, New York; Janet Carter, William J. Taylor Jr., and Lisa M. Ebersole, Everytown Law, New York, New York; for Amicus Curiae Everytown for Gun Safety. Simon J. Frankel, Covington & Burling LLP, San Francisco, California; Paulina K. Slagter, Covington & Burling LLP, Los Angeles, California; J. Adam Skaggs and David Pucino, YOUNG V. STATE OF HAWAII 7 Giffords Law Center to Prevent Gun Violence, New York, New York; Hannah Shearer, Giffords Law Center to Prevent Gun Violence, San Francisco, California; for Amicus Curiae Giffords Law Center to Prevent Gun Violence. Gurbir S. Grewal, Attorney General; Andrew J. Bruck, Executive Assistant Attorney General; Jeremy M. Feigenbaum, Assistant Attorney General; Claudia Joy Demitro, Adam D. Klein and Tim Sheehan, Deputy Attorneys General; Attorney General’s Office, Trenton, New Jersey; Xavier Becerra, Attorney General, Sacramento, California; William Tong, Attorney General, Hartford, Connecticut; Matthew P. Denn, Attorney General, Wilmington, Delaware; Kwame Raoul, Attorney General, Chicago, Illinois; Tom Miller, Attorney General, Des Moines, Iowa; Maura Healey, Attorney General, Boston, Massachusetts; Brian E. Frosh, Attorney General, Baltimore, Maryland; Letitia James, Attorney General, New York, New York; Ellen F. Rosenblum, Attorney General, Salem, Oregon; Peter F. Neronha, Attorney General, Providence, Rhode Island; Mark R. Herring, Attorney General, Richmond, Virginia; Karl A. Racine, Attorney General, Washington, D.C.; for Amici Curiae New Jersey, California, Connecticut, Delaware, Illinois, Iowa, Massachusetts, Maryland, New York, Oregon, Rhode Island, Virginia, and the District of Columbia. Xavier Becerra, Attorney General; Michael J. Mongan, Solicitor General; Thomas S. Patterson, Senior Assistant Attorney General; Samuel P. Siegel and Helen H. Hong, Deputy Solicitors General; Jonathan M. Eisenberg and P. Patty Li, Deputy Attorneys General; Department of Justice, Sacramento, California; for Amicus Curiae State of California. 8 YOUNG V. STATE OF HAWAII John W. Dillon, Gatzke Dillon & Ballance LLP, Carlsbad, California, for Amicus Curiae San Diego County Gun Owners Political Action Committee. Richard L. Holcomb, Holcomb Law LLLC, Honolulu, Hawaii, for Amicus Curiae Hawai‘i Rifle Association. Donald L. Wilkerson, Laupahoehoe, Hawaii, for Amicus Curiae Hawaii Firearms Coalition. Herbert W. Titus, Robert J. Olson, William J. Olson, and Jeremiah L. Morgan, William J. Olson P.C., Vienna, Virginia; Joseph W. Miller, Restoring Liberty Action Committee, Fairbanks, Alaska; for Amici Curiae Gun Owners of America, Gun Owners Foundation, Heller Foundation, Virginia Citizens Defense League, Conservative Legal Defense and Education Fund, and Restoring Liberty Action Committee. David G. Sigale, Law Firm of David G. Sigale P.C., Glen Ellyn, Illinois, for Amicus Curiae Second Amendment Foundation. Donald E. J. Kilmer Jr., Law Offices of Donald Kilmer APC, San Jose, California, for Amici Curiae Madison Society Inc. Calguns Foundation, Firearms Policy Coalition Inc., and Firearms Policy Foundation. John Cutonilli, Garrett Park, Maryland, pro se Amicus Curiae. Neal Goldfarb, Washington, D.C., pro se Amicus Curiae. YOUNG V. STATE OF HAWAII 9 Adita Dynar and Mark Chenoweth, New Civil Liberties Alliance, Washington, D.C., for Amicus Curiae New Civil Liberties Alliance. Jeff Landry, Attorney General; Elizabeth Baker Murrill, Solicitor General; Josiah M. Kollmeyer, Assistant Solicitor General; Department of Justice, Baton Rouge, Louisiana; Steven T. Marshall, Attorney General, Alabama; Mark Brnovich, Attorney General, Arizona; Leslie Rutledge, Attorney General, Arkansas; Christopher M. Carr, Attorney General, Georgia; Lawrence G. Wasden, Attorney General, Idaho; Aaron Negangard, Chief Deputy Attorney General, Indiana; Derek Schmidt, Attorney General, Kansas; Daniel Cameron, Attorney General, Kentucky; Lynn Fitch, Attorney General, Mississippi; Timothy C. Fox, Attorney General, Montana; Douglas J. Peterson, Attorney General, Nebraska; Wayne Stenehjem, Attorney General, North Dakota; Dave Yost, Attorney General, Ohio; Mike Hunter, Attorney General, Oklahoma; Alan Wilson, Attorney General, South Carolina; Jason Ravnsborg, Attorney General, South Dakota; Ken Paxton, Attorney General, Texas; Sean D. Reyes, Attorney General, Utah; Patrick Morrisey, Attorney General, West Virginia; for Amici Curiae States of Louisiana, Alabama, Arizona, Arkansas, Georgia, Idaho, Indiana, Kansas, Kentucky, Mississippi, Montana, Nebraska, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Texas, Utah, and West Virginia. Dan Jackson, Special Deputy Corporation Counsel, Keker Van Nest & Peters LLP, San Francisco, California, for Amici Curiae City and County of Honolulu, County of Kaua‘i, and County of Maui. 10 YOUNG V. STATE OF HAWAII Brian R. Matsui and Samuel B. Goldstein, Morrison & Foerster LLP, Washington, D.C.; Jamie A. Levitt and Janie C. Buckley, Morrison & Foerster LLP, New York, New York; for Amici Curiae Corpus Linguistics Professors and Experts. Michael T. Jean, National Rifle Association of America— Institute for Legislative Action, Fairfax, Virginia, for Amicus Curiae National Rifle Association of America. Matthew J. Silveira, Jones Day, San Francisco, California, for Amici Curiae Social Scientists and Public Health Researchers. Mark D. Selwyn, Wilmer Cutler Pickering Hale and Dorr LLP, Palo Alto, California; Nicholas G. Purcell, Wilmer Cutler Pickering Hale and Dorr LLP, Los Angeles, California; for Amici Curiae Professors of History and Law. Antonio J. Perez-Marques, Sushila Rao Pentapati, Victor Obasaju, Korey Boehm, and Thomas Dec, Davis Polk & Wardwell LLP, New York, New York, for Amicus Curiae Prosecutors Against Gun Violence. Joseph G.S. Greenlee, Firearms Policy Coalition, Sacramento, California; David B. Kopel, Independence Institute, Denver, Colorado; for Amici Curiae Professors of Second Amendment Law, Firearms Policy Coalition, Firearms Policy Foundation, Cato Institute, Madison Society Foundation, California Gun Rights Foundation, Second Amendment Foundation, and Independence Institute. C.D. Michel, Sean A. Brady, and Matthew D. Cubeiro, Michel & Associates P.C., Long Beach, California; James YOUNG V. STATE OF HAWAII 11 Hochberg, James Hochberg Attorney at Law LLLC, Honolulu, Hawaii; for Amici Curiae Hawaii Rifle Association, California Rifle & Pistol Association Inc., and Gun Owners of California. Mark M. Murakami, Damon Key Leong Kupchak Hastert, Honolulu, Hawaii; Jonathan Lowy, Kelly Sampson, and Christa Nichols, Brady, Washington, D.C.; for Amicus Curiae Brady. 12 YOUNG V. STATE OF HAWAII OPINION TABLE OF CONTENTS I. BACKGROUND AND PROCEEDINGS . . . . . . . . . 15 A. Hawai‘i’s Licensing Scheme. . . . . . . . . . . . . . . . . 15 1. History of Firearm Regulation in Hawai‘i . . . 15 2. Hawai‘i’s Current Scheme . . . . . . . . . . . . . . . 18 a. The statute. . . . . . . . . . . . . . . . . . . . . . . . . 18 b. The County of Hawai‘i’s regulations . . . . 19 c. Hawai‘i Attorney General Opinion Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 B. Facts and Proceedings . . . . . . . . . . . . . . . . . . . . . 22 II. THE STANDARDS FOR OUR REVIEW . . . . . . . . . 25 A. Standards of Review of Law and Fact . . . . . . . . . 25 B. Scope of Our Review. . . . . . . . . . . . . . . . . . . . . . . 25 C. Substantive Standards for the Second Amendment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 1. Heller . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 2. Our Post-Heller Framework . . . . . . . . . . . . . . 34 III. PUBLIC CARRY OF FIREARMS AND THE SCOPE OF THE SECOND AMENDMENT . . . . . . . 36 A. The English Right to Bear Arms in Public . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 1. The Royal Decrees . . . . . . . . . . . . . . . . . . . . . 40 2. The Statute of Northampton . . . . . . . . . . . . . . 43 a. The statute. . . . . . . . . . . . . . . . . . . . . . . . . 43 b. Enforcement . . . . . . . . . . . . . . . . . . . . . . . 47 c. Cases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 d. Treatises . . . . . . . . . . . . . . . . . . . . . . . . . . 52 3. The English Bill of Rights . . . . . . . . . . . . . . . 55 B. Colonial Restrictions on the Right to Bear Arms in Public . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 YOUNG V. STATE OF HAWAII 13 C. Post Second Amendment Restrictions on the Right to Bear Arms . . . . . . . . . . . . . . . . . . . . . . . . 62 1. Post-Ratification Restrictions . . . . . . . . . . . . . 64 2. Nineteenth-Century Restrictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 a. The statutes . . . . . . . . . . . . . . . . . . . . . . . . 65 b. The cases. . . . . . . . . . . . . . . . . . . . . . . . . . 73 c. Treatises . . . . . . . . . . . . . . . . . . . . . . . . . . 87 3. Twentieth-Century Restrictions . . . . . . . . . . . 92 D. The Power to Regulate Arms in the Public Square . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96 1. The Basic Rule . . . . . . . . . . . . . . . . . . . . . . . . 96 2. The Exceptions . . . . . . . . . . . . . . . . . . . . . . . 107 a. Classes of persons. . . . . . . . . . . . . . . . . . 107 b. Places . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 c. Licensing and good-cause requirements 108 d. Surety . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 E. Response to the Dissent . . . . . . . . . . . . . . . . . . . 113 F. Application to HRS § 134-9 . . . . . . . . . . . . . . . . 122 IV. OTHER CLAIMS. . . . . . . . . . . . . . . . . . . . . . . . . . . 123 A. Prior Restraint . . . . . . . . . . . . . . . . . . . . . . . . . . 124 B. Procedural Challenge. . . . . . . . . . . . . . . . . . . . . 126 V. CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127 14 YOUNG V. STATE OF HAWAII BYBEE, Circuit Judge: The State of Hawai‘i requires its residents to obtain a license to carry a firearm in public. To satisfy the statutory requirements for an open-carry license, residents must demonstrate “the urgency or the need” to carry a firearm, must be of good moral character, and must be “engaged in the protection of life and property.” Appellant George Young applied for a firearm-carry license twice in 2011, but failed to identify “the urgency or the need” to openly carry a firearm in public. Instead, Young relied upon his general desire to carry a firearm for self-defense. Both of Young’s applications were denied. Young brought a facial challenge to Hawai‘i’s firearm-licensing law under the Second Amendment and the Due Process Clause of the Fourteenth Amendment. The district court upheld Hawai‘i’s statute. We have previously held that individuals do not have a Second Amendment right to carry concealed weapons in public. Peruta v. County of San Diego, 824 F.3d 919 (9th Cir. 2016) (en banc). The question presented in this case is whether individuals have a right to carry weapons openly in public. In order to answer that question, and consistent with the Supreme Court’s decisions in District of Columbia v. Heller, 554 U.S. 570 (2008), and McDonald v. City of Chicago, 561 U.S. 742 (2010), we ask, first, whether Hawai‘i’s law affects conduct protected by the Second Amendment. If so, we then determine if the law can survive the appropriate level of scrutiny. After careful review of the history of early English and American regulation of carrying arms openly in the public square, we conclude that Hawai‘i’s restrictions on the open carrying of firearms reflect longstanding prohibitions and that the conduct they regulate is therefore outside the historical scope of the Second YOUNG V. STATE OF HAWAII 15 Amendment. Accordingly, Hawai‘i’s firearms-carry scheme is lawful. We affirm the judgment of the district court. I. BACKGROUND AND PROCEEDINGS A. Hawai‘i’s Licensing Scheme 1. History of Firearm Regulation in Hawai‘i Hawai‘i law began limiting public carriage of dangerous weapons, including firearms, more than 150 years ago—nearly fifty years before it became a U.S. territory and more than a century before it became a state. Hawai‘i enacted its first statutory regulation of public carry in 1852. The aptly named “Act To Prevent the Carrying of Deadly Weapons” recognized that “the habit of carrying deadly weapons is dangerous to life and the public peace.” Act of May 25, 1852, 1852 Haw. Sess. Laws 19. To combat those risks, Hawai‘i’s pre-territorial legislative council prescribed fines and imprisonment for “[a]ny person not authorized by law, who shall carry, or be found armed with, any bowie- knife, sword-cane, pistol, air-gun, slung-shot or other deadly weapon.” Id. § 1. The Act of May 25, 1852 categorically exempted certain professionals “authorized to bear arms,” such as those “holding official, military, or naval rank . . . when [the firearm was] worn for legitimate purposes.” Id. § 2. Hawai‘i’s regulation of dangerous weapons remained in effect after Hawai‘i consented to annexation as a U.S. territory in 1898. Under the Newlands Resolution, “[t]he municipal legislation of the Hawaiian Islands . . . not inconsistent with this joint resolution nor contrary to the Constitution of the United States nor to any existing treaty of 16 YOUNG V. STATE OF HAWAII the United States, shall remain in force until the Congress of the United States shall otherwise determine.” Resolution of July 7, 1898, 30 Stat. 750. See Territory of Hawai‘i v. Mankichi, 190 U.S. 197, 209 (1903). Hawai‘i’s territorial legislature renewed its 1852 limitations on the carrying of dangerous weapons in a 1905 Act, as amended in 1913. Haw. Rev. Laws, ch. 209, § 3089 (1905), as amended 1913 Haw. Sess. Laws 25, act 22, § 1. Like its predecessors, the 1913 statute made it unlawful to carry deadly weapons unless “authorized by law.” Id. The statute imposed civil and criminal penalties on anyone who carried a “deadly weapon” without prior authorization “unless good cause be shown for having such dangerous weapon.” Id. In 1927, Hawai‘i implemented its first restriction on firearms specifically, as opposed to restrictions on the broader class of “deadly weapons.” In a section entitled “Carrying or keeping small arms by unlicensed person,” the law provided: Except as otherwise provided in Sections 7 and 11 hereof in respect of certain licensees, no person shall carry, keep, possess or have under his control a pistol or revolver; provided, however, that any person who shall have lawfully acquired the ownership or possession of a pistol or revolver may, for purposes of protection and with or without a license, keep the same in the dwelling house or business office personally occupied by him, and, in the case of an unlawful attack upon any person or property in said house or office, said pistol or revolver may be carried in any lawful, hot pursuit of the assailant. YOUNG V. STATE OF HAWAII 17 Act 206, § 5, 1927 Haw. Sess. Laws 209, 209–211. The 1927 Act, which was modeled in part on the Uniform Firearms Act, required a person to obtain a license to carry a “pistol or revolver concealed upon his person or to carry one elsewhere than in his home or office.” Id. § 7. Carry licenses could be issued by the sheriff or a sitting judge after either had determined that applicant was “suitable . . . to be so licensed.” Id. An applicant was deemed “suitable” to carry a firearm upon meeting a citizenship and age requirement and showing a “good reason to fear an injury to his person or property, or . . . other proper reason for carrying a pistol or revolver.” Id. In 1933, the Hawai‘i legislature further refined its concealed-carry licensing scheme. Act 26, § 8, 1933–1934 Haw. Sess. Laws Spec. Sess. 35, 39. To carry a concealed weapon, the applicant had to demonstrate an “exceptional case” and a “good reason to fear injury to his person or property.” Id. The “exceptional case” and “good reason to fear injury” requirements included in the 1933 Act became staples of Hawai‘i’s future firearm regulations. The Hawai‘i legislature included those requirements in its 1961 Act “Relating to Permits to Carry Firearms.” Act 163, 1961 Haw. Sess. Laws 215. The 1961 regulations mirrored those in the 1933 statute and required an applicant to demonstrate an “exceptional case” and a “good reason [for the applicant] to fear injury to his person or property” before publicly carrying a firearm. Id. § 1. Whereas the 1933 Act only applied to concealed carry, however, the 1961 Act announced a new regulatory scheme for open carry. An individual seeking to carry a firearm openly in public was required to demonstrate “the urgency of the need” to carry and must be “engaged in the protection of life and property.” Id. If the applicant made such a showing 18 YOUNG V. STATE OF HAWAII and was not otherwise prohibited from possessing a firearm, the chief of police had discretion to grant the carry application. Id. (“[T]he respective chiefs of police may grant a license . . . .”). 2. Hawai‘i’s Current Scheme a. The statute. Hawai‘i’s current scheme allows individuals to possess firearms under a variety of circumstances. First, individuals who are not members of law enforcement, the armed forces, or certain federal agencies and wish to carry firearms in places outside of their homes, places of business or sojourns must obtain a license from the county chief of police. Hawai‘i Revised Statutes (HRS) § 134-9(a). Second, individuals may possess firearms in their homes, places of business, and sojourns. Id. § 134-23. Third, persons who are authorized by their public employers, including law enforcement, the armed forces, and certain federal agencies, are exempt from other restrictions and may carry in public. Id. § 134-11(a). Fourth, any person, sixteen years or older “may carry and use any lawfully acquired rifle or shotgun and suitable ammunition while actually engaged in hunting or target shooting.” Id. § 134-5(a). Additionally, “[a] person may carry unconcealed and use a lawfully acquired pistol or revolver while actually engaged in hunting game mammals.” Id. § 134-5(c). Hawai‘i’s public carry licensing scheme is substantially the same today as it was in 1961. Hawai‘i continues to distinguish between concealed carry and open carry, although it is not clear that the difference is particularly significant. To obtain a concealed carry license from a county chief of police, a person must first show “an exceptional case” and a “reason to fear injury to [his or her] person or property.” YOUNG V. STATE OF HAWAII 19 HRS § 134-9(a). As to open carry, the statute states in relevant part: Where the urgency or the need has been sufficiently indicated, the respective chief of police may grant to an applicant of good moral character who is a citizen of the United States of the age of twenty-one years or more, is engaged in the protection of life and property, and is not prohibited under section 134-7 from the ownership or possession of a firearm, a license to carry a pistol or revolver and ammunition therefor unconcealed on the person within the county where the license is granted. Id. Many of the statute’s requirements are objective. For instance, whether the applicant meets the citizenship, age, or legal-ownership requirements may be determined by the reviewing chief of police by a simple review of the application and law enforcement databases. On the other hand, “the urgency or the need” for the license and the applicant’s participation in “the protection of life and property” appear to be subjective requirements not discoverable by reference to a law enforcement database. b. The County of Hawai‘i’s regulations. In October 1997, the County of Hawai‘i—where Young lives and where he applied for several carry permits—promulgated county- wide rules to evaluate permit applications under § 134-9. See HRS § 91-3 (detailing the rule-making process for county boards, county commissions, and other agencies authorized by law to make rules). These “Rules and Regulations Governing the Issuance of Licenses to Carry Concealed and 20 YOUNG V. STATE OF HAWAII Unconcealed Weapons” outline the process the chief of police would follow in reviewing carry applications under § 134-9. The county regulation imposed different rules for concealed arms and for unconcealed arms consistent with § 134-9’s bifurcation, but a brief review of the regulations reveals several inconsistencies between the state statute and the county’s administration. At the outset, it is clear that Hawai‘i County’s regulations are more demanding than § 134-9. For instance, the regulations seem to consider open- carry permit applications to be available only to “private detectives and security guards.” In fact, the first subheading reads “Rules and Regulations Governing the Carrying of Concealed Weapons and the Carrying of Weapons by Private Detectives and Security Guards.” The regulation also provides the chief of police a mechanism by which to cancel a previously issued carry permit upon termination of the applicant’s employment. Meanwhile, § 134-9 does not impose a professional requirement on the applicant, nor does it distinguish between applications by security guards and applications by other citizens. The county regulation also applies to a broader class of weapons than does § 134-9. Whereas § 134-9 applies only to the public carry of “a pistol or revolver and ammunition therefor,” the county regulation defines “firearm” to include “rifles, shotguns, automatic firearms, noxious gas projectors, mortars, bombs, and cannon[s].” Section 134-9 did not contemplate any of those classes of arms. Similarly, the county regulation also applies to non-firearm “weapons” that could be concealed on the person, including “knives, blackjacks, batons, night sticks, and chemical agents designed to temporarily subdue or incapacitate a person.” Again, § 134-9 is silent on such weapons. YOUNG V. STATE OF HAWAII 21 c. Hawai‘i Attorney General Opinion Letter. After this litigation began, the Hawai‘i Attorney General issued a formal opinion interpreting § 134-9’s requirements and clarified that § 134-9 does not reserve open-carry permits to security guards. See State of Haw., Dep’t of the Att’y Gen., Opinion Letter No. 18-1, Availability of Unconcealed-Carry Licenses (Sept. 11, 2018) (https://ag.hawaii.gov/wp-content /uploads/2018/09/AG-Opinion-No.-18-1.pdf) (Att’y Gen. Letter). The Attorney General unequivocally rejected Hawai‘i County’s interpretation that an open-carry permit applicant must demonstrate a professional need to carry, such as being a private investigator or security guard. Id. at 3–4. The Attorney General concluded that such a showing would be inconsistent with § 134-9, which “does not limit unconcealed-carry licenses to individuals employed as private security officers.” Id. at 6. All that the statute requires is that the applicant (1) meet the objective qualifications; (2) be of good moral character; (3) demonstrate “sufficient need”; and (4) present no other reason to be disqualified. Id. at 6–7. According to the Attorney General’s Opinion Letter, an applicant’s need is “sufficient” if it is urgent and is related to “engage[ment] in the protection of life and property.” Id. at 7 (citing HRS § 134-9). The urgency requirement “connote[s] an immediate, pressing, and heightened interest in carrying a firearm.” Id. at 8. Coupled with the requirement that the applicant be “engaged in the protection of life and property,” an applicant must demonstrate more than a “generalized concern for safety.” Id.; see also id. at 7 (noting that the statute only requires an applicant to show a need for armed self-defense “that substantially exceeds the need possessed by ordinary law-abiding citizens”) (citing Drake v. Filko, 724 F.3d 426, 428 & n.2 (3d Cir. 2013)). The Attorney General provided several examples of applicants who would 22 YOUNG V. STATE OF HAWAII plausibly qualify for an open-carry license regardless of their profession.1 The Attorney General’s Opinion Letter did not repeal Hawai‘i County’s regulations, but its interpretation of state law is considered “highly instructive.” See Kepo