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 The law also created an unpublished assault-style firearms roster that officials can amend administratively.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 after Capen reached the First Circuit, specifically targeting the Chapter 135 version of the ban. The two cases are not formally consolidated and proceed on separate tracks. Hanlon remains in the district court while Capen awaits further proceedings.

SCOTUS Context

The Supreme Court is considering certiorari petitions in several related assault weapons cases from other circuits. SCOTUS petition No. 25-566 (Grant v. Higgins) involves Connecticut's assault weapons ban and raises substantially similar questions about bans on commonly owned semiautomatic firearms. A grant of certiorari in any related case could directly reshape the trajectory of Hanlon and other pending Massachusetts challenges.

Current Status

As of May 2026, Hanlon v. Campbell remains in the U.S. District Court for the District of Massachusetts. No preliminary injunction motion has been resolved and no trial date has been set.

Note: Hanlon v. Campbell is pending in the U.S. District Court for the District of Massachusetts, not the First Circuit Court of Appeals. It should not be confused with Capen v. Campbell, which was decided by the First Circuit in April 2025. The slug for this article contains "first-circuit" for historical reasons; the case is a district court proceeding.

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.