On February 13, 2014, just in time for Valentine’s Day, the Ninth Circuit expressed its love for constitutional order by firing an arrow through the heart of California’s arbitrary handgun carry licensing scheme. The court’s decision in Peruta v. County of San Diego1 effectively struck down the Golden State’s requirement that individuals wishing to carry a handgun in public for self-defense demonstrate “good cause”2 to exercise what is, in fact, a fundamental constitutional right.3
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