If a place is truly “sensitive,” the state must provide armed security.

Stephen Halbrook | 1.20.2026 9:49 PM

Before the Supreme Court heard oral argument yesterday in Wolford v. Lopez, I covered a range of Second Amendment issues central and tangential to the dispute over Hawaii's no-carry default rule. In opposition to the Court's Bruen decision, Hawaii enacted a "Vampire Rule" requiring prior consent for a licensed armed person to enter private property open to the public.  Think stopping at a gas station or convenience store.

One issue that was alluded to several times in the argument is the scope of the so-called "sensitive places" limitation on the Second Amendment's protections. Wolford is not really a "sensitive places" case—it is actually about the handful of places Hawaii did not separately declare "sensitive," since the no-carry-default rule applies only to places that the state has not made no-carry-no-matter-what. Nevertheless, it is quite probable that in dealing with the issue the Court will touch on, and possibly explain, its previous statements on the issue.

The Court's "sensitive places" dicta have been the source of some significant confusion for courts and litigants alike. In District of Columbia v. Heller, as it struck down D.C.'s handgun ban, the Court cautioned that "nothing in our opinion should........

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