Hanlon v. Campbell: NRA and GOAL Challenge Massachusetts Assault-Style Firearms Ban

Hanlon v. Campbell is a federal Second Amendment challenge to Massachusetts' ban on assault-style firearms filed by the National Rifle Association, the Gun Owners' Action League (GOAL), Pioneer Valley Arms, and four individual plaintiffs on August 21, 2025, in the U.S. District Court for the District of Massachusetts.^[1]

Plaintiffs

The four individual plaintiffs are law-abiding Massachusetts residents with valid Licenses to Carry:

• Peter Hanlon, a retired Captain in the Massachusetts Environmental Police
• David Worman, an orthopedic surgeon
• Nancy Trehub, a retired prosecutor
• Jeffrey Sacks, an oral and maxillofacial surgeon

The organizational plaintiffs are the NRA, GOAL, and Pioneer Valley Arms, a licensed Massachusetts firearms dealer.

What Is Being Challenged

The complaint targets the assault-style firearms ban enacted through Chapter 135 of the Acts of 2024.^[2] Chapter 135 broadened the pre-existing assault weapons ban by replacing the "assault weapon" definition with the wider "assault-style firearm" category, adding functional characteristics tests and a new copy-or-duplicate test. The law also created an unpublished assault-style firearms roster that officials can amend administratively.

The plaintiffs argue that the ban deprives law-abiding citizens of their Second Amendment right to keep and bear firearms that are in common use for lawful purposes across the United States, including numerous makes and models of semiautomatic rifles, shotguns, and handguns.

Legal Theory

The complaint relies on the Supreme Court's 2022 decision in NYSRPA v. Bruen,^[3] which established the historical tradition test for evaluating firearms regulations. The plaintiffs acknowledge that the First Circuit previously upheld Massachusetts' assault weapons ban in Worman v. Healey (2019) and affirmed denial of a preliminary injunction in Capen v. Campbell (2025), but argue those decisions were wrongly decided or applied an incorrect framework.

Relationship to Capen v. Campbell

In April 2025, the First Circuit decided Capen v. Campbell, affirming the denial of a preliminary injunction against an earlier challenge to the Massachusetts assault weapons ban.^[4] Hanlon was filed later and specifically targeted the Chapter 135 version of the ban. On October 17, 2025, the district court consolidated Hanlon into the lead Capen docket.^[5]

SCOTUS Context

On June 30, 2026, the Supreme Court granted certiorari in two related assault weapons cases from other circuits and consolidated them: Grant v. Higgins (No. 25-566), challenging Connecticut's ban, and Viramontes v. Cook County (No. 25-238), challenging the Cook County, Illinois ban. The consolidated cases raise substantially similar questions about bans on commonly owned semiautomatic firearms, and the Court will decide whether the Second Amendment protects their possession, with argument expected in the October 2026 Term. The eventual ruling could directly reshape the trajectory of Hanlon and other pending Massachusetts challenges.

Current Status

On July 9, 2026, the district court stayed the consolidated Capen/Hanlon proceeding at the parties' joint request while the Supreme Court considers Grant v. Higgins and Viramontes v. Cook County. The court canceled the July 10 status conference and directed counsel to notify the clerk when they are ready to proceed.^[6]

Note: Hanlon is a district-court case consolidated into Capen. The article slug contains "first-circuit" for historical reasons; Hanlon itself has not produced a First Circuit merits decision.

Practical Impact

The Massachusetts assault-style firearms ban remains in full effect. The pendency of Hanlon does not create any exception to current law. Residents must continue to comply with the Chapter 135 framework unless and until a court issues an injunction or final ruling to the contrary.

Related Appellate Decisions

The First Circuit's later Recchia decision affirmed dismissal of a facial challenge but did not decide an unpreserved magazine argument or other unraised arguments.^[7] The en banc Third Circuit's contrary 2026 decision concerning New Jersey restrictions is not binding in Massachusetts.^[8]