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A Victory for the Second Amendment: FPC v. Bondi (Sept. 30, 2025) and Its Implications on “Sensitive Area” Bans

On September 30, 2025, the United States District Court for the Northern District of Texas issued a critical decision in Firearms Policy Coalition v. Attorney General Pam Bondi. In that ruling, the court struck down the federal prohibition on firearm possession, storage, and carry on U.S. Postal Service premises and related federal properties.

This decision represents a reaffirmation—at least in the court’s view—of robust protections for the right to keep and bear arms, even in places historically regulated by federal statute. It signals a recognition that blanket bans on firearms in certain locations must meet close constitutional scrutiny rather than simply being presumed to be acceptable.

Key Legal Takeaways from the Decision

While the full opinion should be carefully parsed, several principles emerge that make it a potential precedent or point of persuasion for future challenges:

  1. No Free Pass for Location Bans
    The court rejected the notion that certain “sensitive places” automatically fall outside the slings and arrows of Second Amendment scrutiny. Even in properties like post offices—traditionally considered federal domains—the government must show that its restrictions are consistent with the nation’s historical tradition of firearm regulation.
  2. Historical Tradition as the Benchmark
    Under the post-Bruen framework (i.e. New York State Rifle & Pistol Association v. Bruen), the government must show that a challenged firearms restriction is analogous to historic regulation. The FPC v. Bondi court evidently held that the federal ban lacked sufficient grounding in historical analogues, and thus failed constitutional muster.
  3. Carve-Outs for Law Enforcement (“No New Rights for Government”)
    As is common in these cases, the decision preserved law-enforcement exemptions. Yet by striking the ban for ordinary citizens, the court underscores that non-officials are not to be entirely disarmed in places the government designates.
  4. A Sword for Future Challenges
    The ruling gives arms-rights litigants ammunition (pun intended) to argue against other categorical location bans—whether at federal, state, or municipal levels. Subsequent cases may press the logic of FPC v. Bondi to more local settings.

In sum, FPC v. Bondi is a shot across the bow to governments seeking to impose sweeping “no guns allowed anywhere” rules without meeting constitutional tests.


The Massachusetts Law Banning Gun Carry in Government Buildings

Massachusetts has recently enacted sweeping “reforms” in its already constitutionally dubious firearms law regime under the “Act Modernizing Firearms Laws” (St. 2024, c. 135), which took effect (via emergency implementation) in October 2024.

Among the new restrictions is a prohibition on carrying firearms into government buildings, with an explicit exemption for law enforcement.

At the state level, the Massachusetts Department of Capital Asset Management & Maintenance (DCAMM) also has administrative rules barring visitor possession of weapons (including firearms) in state-managed facilities, disallowing secure storage or entry by persons who refuse to declare or surrender weapons.

Thus, under present law, a Massachusetts resident (non-law enforcement) with a valid license to carry must nonetheless leave their firearm outside when entering most governmental buildings.

Potential Constitutional Tension

From a Second Amendment perspective, the Massachusetts government-building carry ban may well contrast poorly with the rationale embraced in FPC v. Bondi. Here is how the parallels might map out:

Analytical FactorFPC v. Bondi (Federal Post Office Ban)Massachusetts Govt. Building Ban
Type of propertyFederal domain (USPS buildings and related properties)State and local government buildings
Who is barredPrivate persons (non–law enforcement)Private persons (non-law enforcement)
ExemptionsLaw enforcementLaw enforcement
Burden on Second Amendment rightsAbsolute prohibition in those spacesAbsolute prohibition within those buildings
Historical analogue requiredMust show tradition of disarming in analogous spacesWould need historical precedent for disarming citizens at government buildings

If FPC v. Bondi holds that even a federal domain cannot be summarily exempted from constitutional scrutiny, the Massachusetts law’s categorical ban may invite similar constitutional challenges. Indeed, a litigant in Massachusetts could argue:

  • No tradition of disarming citizens in government buildings: There is, at best, scant evidence that, at the founding or through the 19th century, states routinely barred gun possession in courthouses, town halls, administrative offices, or similar buildings for ordinary citizens. (Much less in all government buildings across the board.)
  • Must pass the Bruen standard: Under Bruen, restrictions must be consistent with the historical tradition of firearms regulation, not just with modern safety policy goals. The Massachusetts statute’s sweeping reach may struggle to find analogues in early American or colonial practice.
  • Overbreadth and undermining self-defense: Government buildings are numerous and cover many spheres of daily life (e.g., tax offices, city halls, permit offices). A blanket ban weakens an individual’s ability to carry for self-defense in places where modern threats may exist, raising a question whether the government’s interest sufficiently justifies the complete removal of the self-defense right in those buildings.
  • Risk of slippery slope: If the state can ban in all its own buildings, might it extend to all public spaces? The logic of exclusion could expand unless bounded by constitutional guardrails.

Thus, FPC v. Bondi offers not only encouragement but a potentially persuasive reasoning template for challenging the Massachusetts ban. A Massachusetts federal or state court might adopt the FPC reasoning and require that the state show historical analogues for disarming in similarly situated buildings—something Massachusetts may struggle to do.

The FPC decision strengthens the argument that location bans—even in government buildings—cannot be simply rubber-stamped. They must survive constitutional analysis, especially in modern times when individuals face new threats.


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