Ninth Circuit Forced to Deliver Rare Second Amendment Win Against Hawaii’s ‘Vampire Rule’

Summary

The Ninth Circuit Court of Appeals, on August 10, 2026, reinstated an injunction against Hawaii's private-property "vampire rule" (HRS § 134-9.5) and parts of HRS § 134-9.1(a)(1) in *Wolford v. Lopez*. This action followed a Supreme Court reversal of the Ninth Circuit's earlier decision, which found Hawaii's default ban on private property carry unconstitutional under the Second and Fourteenth Amendments. The ruling marks a significant win for Second Amendment rights, particularly impacting similar "default no-carry" laws in other states.