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New York State Rifle & Pistol Association v. City of New York

Supreme Court of the United States · 2020 · Constitutional Law

Constitutional LawSecond AmendmentMootnessVacaturRemandmootnessSecond Amendmentdeclaratory relief

Facts

Petitioners challenged a City rule that prevented them from transporting firearms to a second home or shooting range outside New York City, claiming the rule violated the Second Amendment. In their complaint, they sought declaratory and injunctive relief against enforcement of the rule to the extent it barred that transport. After the Supreme Court granted certiorari, the State amended its firearm licensing statute and the City amended its rule to allow transport to a second home or shooting range outside the city. Petitioners then argued that the new rule might still infringe their rights and also asserted they might seek damages regarding the old rule.

Issue

Whether petitioners' challenge to the City's old firearm transport rule remained a live controversy after the State and City changed the governing law to permit the very transportation petitioners had requested. If the original claim was moot, the Court also had to decide the appropriate appellate disposition in light of possible residual claims under the new rule and a possible damages claim regarding the old rule.

Rule

When a case becomes moot on appeal, the Court's ordinary practice is to vacate the judgment and direct dismissal. But when mootness results from a change in the legal framework governing the case, and the plaintiff may have some residual claim under the new framework that was understandably not asserted previously, the proper course is to vacate the judgment and remand for further proceedings so the parties may, if necessary, amend their pleadings or develop the record more fully.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lena Ortiz sued the City of Denver in federal court, seeking only declaratory and injunctive relief against a city ordinance that barred licensed falconers from transporting birds to training fields outside city limits. After the court of appeals upheld the ordinance and the Supreme Court granted certiorari, Colorado enacted a statute preempting such local restrictions and Denver amended its ordinance to allow transport to out-of-city training fields, exactly as Lena's complaint had requested.

What is the most appropriate disposition of Lena's case under the majority rule?

Explanation. When the governing law changes on appeal and gives the plaintiff the precise declaratory and injunctive relief requested as to the old rule, the original claim becomes moot. The majority stated that the ordinary practice is vacatur with directions to dismiss, but where mootness stems from a change in the legal framework and some residual claim may remain under the new framework, the proper course is vacatur and remand for further proceedings. (Derived from New York State Rifle & Pistol Association v. City of New York (n.d.).)