Today a 2-1 Ninth Circuit panel held that Hawaii’s near-total prohibition on the carrying of handguns for lawful self-defense violates the Second Amendment right to bear arms. Under binding precedent from a previous case, Peruta v. San Diego (Peruta II), concealed carry is not a Second Amendment right. However, Hawaii requires a license for either concealed or open carry, and almost never issues licenses for either. Under today’s ruling, Hawaii may not limit open carry licenses only to persons who are security guards. The opinion is here.