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Supreme Court Sets Hawaii Straight on Second Amendment
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Supreme Court Sets Hawaii Straight on Second Amendment

This morning, the Supreme Court issued its opinion in Wolford v. Lopez, an important opinion clarifying the scope of the Second Amendment’s right to bear arms outside of the home. The issue before the Court this time was whether the 9th Circuit Court of Appeals erred in holding that Hawaii may presumptively prohibit the carry of handguns by licensed concealed carry permit holders on private property open to the public unless the property owner affirmatively gives express permission to the handgun carrier. In a 6-3 decision, Justice Samuel Alito wrote for the majority, holding that Hawaii’s law violates the Second and Fourteenth Amendment.  The Second Amendment Cases As a refresher, in 2008, the Supreme Court ruled in District of Columbia v. Heller that Second Amendment protects an individual right to possess a firearm not connected with service in a militia and to use that firearm for lawful purposes such as self-defense within the home. Two years later, the Supreme Court ruled in McDonald v. City of Chicago that the Second Amendment right of individuals to keep and bear arms in self-defense applies against state and local governments as well as the federal government. As the Supreme Court said in McDonald, “The Second Amendment does not protect a second-class right, but one that is fundamental to our scheme of ordered liberty and applicable against the states through the Fourteenth Amendment.” Unfortunately, many lower courts have refused to treat Heller or McDonald with respect, upholding gun control laws across the country. In 2022, the Supreme Court issued a 6-3 opinion in New York State Rifle & Pistol Association v. Bruen. In Bruen, the Court held that New York’s Sullivan Act—a 1911 law requiring individuals to demonstrate “proper cause” to obtain a license to carry a handgun in public—violated the Second Amendment because it imposed a discretionary standard on the exercise of a constitutional right. The Court held that the Second Amendment guarantees a “general right to publicly carry arms for self-defense.” The implications of this ruling far exceeded 20th-century state law: The Court made clear that modern gun regulations must adhere to historical practice and a constitutional reading of the Second Amendment. Hawaii Gun Law Response States with the most restrictive gun laws responded legislatively. On June 2, 2023, the Hawaii Legislature passed Act 52, a staggering overhaul of firearm regulations. While the law allowed for licensed public carry, it established a sprawling list of “sensitive places” where public carry was not permitted. Act 52 established “a default rule with respect to carrying firearms on private property of another person.” The stated purpose of the rule was to protect “the right of private individuals and entities to choose for themselves whether to allow or restrict the carrying of firearms on their property.” These areas included schools, government buildings, parks, stadiums, movie theaters, beaches, and more. The law also specified that for private businesses, express authorization, in the form of signage, words, or writing, was required as permission to carry a firearm onto the premises. Despite these restrictive terms, the state maintained it had followed the Bruen framework. Jason Wolford, a Hawaii concealed-carry license-holder, and two others similarly situated, sued the Hawaii Attorney General claiming that Act 52 violated the Second Amendment. Wolford argued that the law’s list of prohibited areas was so exhaustive that it all but nullified his permit. This form of compliance reflects what critics have described as the “vampire rule,” a regulatory construct that preserves the right to bear arms in theory while rendering it functionally unusable in practice. Under Hawaii’s approach, firearms are presumptively banned on private property open to the public unless the owner affirmatively grants permission, flipping the traditional presumption that a constitutional right may be exercised without permission. Backed by the Hawaii Firearms Coalition, Wolford sought relief in the U.S. District Court for the District of Hawaii. U.S. District Court Judge Leslie Kobayashi granted a partial temporary restraining order. Despite the State’s claim that there was a historical analogue to Hawaii’s law, Judge Kobayashi found the evidence for these claims to be insufficient. Further, Judge Kobayashi contended that the state had overreached by presuming bans on behalf of public property owners, rather than deferring to a property owner’s fundamental right to exclude. Kobayashi concluded that because plaintiffs had continued to carry their firearms in prohibited areas, they faced immediate irreparable harm in the form of potential criminal charges. The State appealed to the Ninth Circuit, which evaluated Hawaii’s laws alongside a similar set of laws enacted in California. The court affirmed in part and reversed in large part the lower court injunction. While California’s requirement for a physical sign was deemed too rigid, Hawaii’s rule was upheld. Analogizing historical trespass laws, the court reversed the injunction because the law allowed for consent to be given orally, in writing, or through signage. Unlike Judge Kobayashi, the Ninth Circuit allowed for a less stringent standard in the application of historical practice. The State need only “evince a principle” in historical practice regulating firearms in places relevantly like those covered by the challenged law. Appellees requested en banc review but were denied. On Oct. 3, 2025, the Supreme Court granted review. On Jan. 20, 2026, the U.S. Supreme Court held oral argument. Alan Beck, arguing for petitioners, claimed that Hawaii’s law prevented licensed concealed carry in approximately 97% of public areas. Beck also accused the state of improperly bolstering the historical record with Black Codes, which he characterized as discriminatory anti-poaching laws meant to target African Americans. Neal Katyal, attorney for respondents, took a different tack. Katyal framed the debate as centering on two legal rights: the right to bear arms and the property right to exclude. The right to bear arms, Katyal argued, is insufficient to establish implied consent onto private property. Allowing states flexibility to balance both rights as “laboratories” of democracy, he contended, is the most prudent approach in adapting to a post-Bruen world. The Holding The Court held that the restrictions imposed by Hawaii’s law fell within the plain text of the Second Amendment. The law departed sharply from the standard common law rule on access to private property held open to the public. Under the common law rule, everyone, including those lawfully carrying firearms, could enter unless expressly prohibited from doing so. The Hawaii law flipped the script: no one carrying a firearm could enter private property open to the public without the property owner’s express authorization. At the outset, the Court noted that owners of establishments that are open to the public can admit or exclude people who are carrying guns for self-defense under either the common law or Hawaii law. But the new law “unquestionably imposes a new and significant burden on the exercise of the right recognized in Bruen.” The historical analogues proffered by Hawaii do not support the constitutionality of its new default rule. Justice Elena Kagan dissented, writing that the Hawaii law is a “modern-day analogue of colonial and founding era laws that similarly prohibited carrying firearms onto private property.” Justice Ketanji Brown Jackson dissented, joined by Justice Sonia Sotomayor, writing that this case is not about the Second Amendment, but rather a property rights issue, and as such, the law is constitutional as it preserves private property owner’s rights to exclude people from their property.

Five Reasons Why Obergefell Remains Constitutionally Vulnerable
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Five Reasons Why Obergefell Remains Constitutionally Vulnerable

The Supreme Court’s 2015 decision in Obergefell v. Hodges stands as one of the most egregious examples of judicial activism in modern history. In a single stroke, five unelected lawyers redefined the timeless institution of marriage for the entire nation, bypassing the Constitution, the democratic process, and millennia of human experience rooted in biblical truth and human nature. Like Roe v. Wade has been, Obergefell must be overturned. Here are five compelling reasons. First, Obergefell was unconstitutional from the day it was decided. Justice Samuel Alito rightly declared in Dobbs v. Jackson Women’s Health Organization that Roe was “egregiously wrong from the start.” The same verdict applies to Obergefell. The Constitution makes no mention of a right to same-sex marriage. It contains no substantive due process clause empowering judges to impose their policy preferences on the states. The decision rested not on the text, history, or tradition of our founding document, but on the political desires of activist justices. Marriage, as understood by the Founders and by virtually every society until very recently, is the union of one man and one woman. The Court had neither the constitutional nor the moral authority to rewrite that definition. Second, the most constitutionally faithful justice on the Supreme Court has already called for its reversal. In his concurrence in Dobbs, Justice Clarence Thomas urged the Court to reconsider all of its substantive due process precedents, explicitly naming Obergefell. Thomas correctly noted that the Due Process Clause guarantees fair procedures, not a license for judges to discover new “fundamental rights” untethered from the Constitution’s text. So-called substantive due process has a troubled history and destroys our constitutional order by exalting judicial will over the people’s authority. Thomas’ call was clear: these demonstrably erroneous decisions must be corrected. Third, a majority of the current justices already understand that the Constitution does not prohibit states from protecting natural marriage. Clarence Thomas, Samuel Alito, and John Roberts all dissented in Obergefell.  Roberts even warned that the majority had abandoned judicial restraint for raw policymaking. The three newest Republican-nominated justices—Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett—joined the Court that correctly returned abortion to the democratic process in Dobbs. They grasp that the Constitution’s text does not create a national right to redefine marriage. Barrett, both as a law professor and during her Supreme Court confirmation hearings, has explained that court precedents remain subject to reversal unless they qualify as “super precedents,” which are deeply embedded in law and culture. Obergefell is no super precedent. Justice Kennedy’s anxious post-decision defenses of the ruling, combined with ongoing state-level efforts to prepare for its possible overturn, prove that Obergefell has never been widely accepted and therefore can—and should—be reversed. Fourth, the slippery slope unleashed by Obergefell has been steep and damaging. What began as a claim for same-sex marriage quickly morphed into a radical transgender agenda that denies biological reality. Americans are rightly pushing back against LGBT ideology in schools, sports, and medicine. Meanwhile, faithful Christians—bakers, photographers, and adoption agency employees—have faced relentless persecution for simply living out their biblical convictions about marriage. The promise that Obergefell would bring “live and let live” tolerance proved horrendously false. Instead, it empowered a sexual revolution that punishes dissent and marginalizes those who hold to the traditional—and biblical—understanding of family that built Western civilization. Fifth, the impact on children—a key justification offered by Justice Kennedy—has not aged well. Kennedy claimed his decision served the dignity of children living in same-sex households. Yet multiple studies show that children thrive best with a married mother and father. Those raised in same-sex households face elevated risks in emotional well-being, educational outcomes, and long-term family stability. Using innocent children as instruments for adult ideological experiments is profoundly unjust. Society has a solemn duty to prioritize the welfare of innocent children over political correctness. The American people deserve the chance to deliberate these profound questions through their elected representatives, as the Constitution demands. Returning marriage policy to the people would restore self-government and allow citizens to protect both children and the institution of marriage—just as they did in nearly every state, including California, before Obergefell. As Americans, we acknowledge the natural and Biblical roots of Western morality and recognize that marriage is a covenant between one man and one woman. As constitutionalists, we insist that judges interpret the law as written, not as woke ideologues would like it to be. As adults, we cannot allow a failed social experiment to continue harming children who need both a mother and a father.  Obergefell is a moral, constitutional, and familial tragedy. The Supreme Court must reverse it without delay. We publish a variety of perspectives. Nothing written here is to be construed as representing the views of the Daily Signal.

Ireland Is Being Repressed—By the Irish
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Ireland Is Being Repressed—By the Irish

When a man in Belfast, Northern Ireland, was stabbed and nearly beheaded by a Sudanese migrant two weeks ago, the governmental response was unnervingly familiar: Remain calm, suppress the truth, and scold the native people for their strong reaction against a select foreign class. Welcome back to 1726. The Irish people’s long struggles with British rule resulted in an independent Republic of Ireland (Éire) a century ago, and a Northern Ireland that remained part of the United Kingdom. After decades of terrorism and sectarian violence, the U.S.-brokered Good Friday Agreement of 1998 brought peace to the land. Ironically, the hard-won Republic of Ireland is now run by the ideological descendants of the empire their ancestors despised. And for Northern Ireland, the issue is twofold: Although part of the U.K., the North has maintained an open border with the Republic. This leaves it victim to poor immigration policies of both London and Dublin. The recent attempted murderer had initially entered Dublin, and in 2023, crossed easily into Belfast, where he was granted asylum. Neither government has taken any accountability. Just as in the 18th century, the British government today prosecutes citizens for speech deemed unacceptable or inimical to state interests. In both eras, criticism of favored foreigners—the English then, third-world migrants today—draws particular ire. After the attempted beheading, Northern Irish lawmakers immediately attempted to suppress the harrowing footage. Claire Hanna, leader of the Social Democratic and Labour Party, said, “[T]he video will create fear and shock. No good will come of sharing it.” Perhaps that’s why, as Cormac Lucey points out, the attack failed to make the front pages of the Irish Times and the Irish Independent, two top national publications. Yet both later ran lead stories on the ensuing riots, in a classic example of “Conservatives Pounce” media bias. The fury of the people of Belfast—not its cause—was swiftly condemned. Just like in the U.S., the barbarous act of a migrant wasn’t leading news for Irish legacy media, but the native backlash was. Rather than reevaluate their asylum and immigration laws, both U.K. and Irish authorities doubled down on protecting the status quo. Outgoing Prime Minister Sir Keir Starmer expressed sympathy for the victim and thanked those who intervened, but he was silent on the policy failures that led to a psychotic illegal immigrant being released to wander the streets.For their part, the Oireachtas (the legislative assembly for the Republic of Ireland) voted directly after the attack to adopt the EU Migration Pact without discussion. Under this law, EU member states will be subject to a policy of “mandatory solidarity”: If one or more member states are struggling to accept excessive numbers of migrants, other member states will be forced either to provide them assistance in doing so or to take the migrants in their stead. Most of this migration is of supposed asylum seekers, whose applications are approved on generous terms and few of whom are deported even if denied. The 72% of Irish who voted in 2024 for “very strict limits” on migration were not even granted the courtesy of a debate. Anglican landlords ruled the native peasantry for centuries with little care for their opinions. The Oireachtas today, like its eighteenth-century predecessor, still cares less for the Irish people than it does for the EU, a foreign body with sparse connection to its local constituents. This crisis of poor representation was evident in Ireland’s recent presidential elections. After right-wing candidates Maria Steen and Nick Delehanty failed to gain governmental sanction for their campaigns, 13% of Irish voters spoiled their ballots in protest. When the outrageous video of the attempted beheading inevitably went viral, the people of Belfast took to the streets in protest. Unfortunately, some of the protestors turned to violence. Dean Céitinn, the director of Breaking Point, expressed their frustration at their vulnerability to preventable violent crime from uninvited migrants. “People’s options are very limited. It’s just a type of brutality that’s so unprecedented here. And it keeps getting more common,” he said. It was only then that British and Irish leaders began responding forcefully. In the face of an attempted beheading, authorities like Ryan Henderson, the deputy chief of the Belfast police, had responded with the meek tone of an ineffective parent cowed by a toddler: “I understand that last night’s attempted murder will leave people feeling a range of emotions.” In our day, however, the forces seeking to control the narrative in Ireland—and elsewhere—face a nascent source of pushback. One they haven’t had to contend with in a very long time. For centuries, Ireland and what is now Northern Ireland were racked with political-sectarian violence. In 1729, Irish satirist Jonathan Swift wrote about the threat of subversive “Papists” seeking to overthrow the British government. In more recent memory, the Troubles saw roughly three decades of violence and terrorism, resulting in over 30,000 dead or injured. Of those killed, more than half were innocent bystanders or noncombatants. Until this point, persistent violence and grave suspicion between Catholics and Protestants in Belfast had precluded the faintest alignment. Now, confronting what many have described as an invasion, there has emerged what Aris Roussinos calls “the first glimmerings of an attempted and distrustful rapprochement.” That represents the first time in living memory that the citizens of Belfast have recognized a common, external threat. All because of a government which has silenced and ignored them.In America, elites should take note.

Gov. DeWine Vetoed Voter ID for Mail-In Ballots. What’s Next?
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Gov. DeWine Vetoed Voter ID for Mail-In Ballots. What’s Next?

On Wednesday night, Gov. Mike DeWine, R-Ohio, vetoed House Bill 472, which in its final form included provisions requiring a photo ID for mail-in ballots. The fight for voter integrity does not appear to be over in the Buckeye State, however. In vetoing the bill, DeWine released a statement noting that “the bill “would not discourage fraud, would not add any real security, and would create an additional and significant burden for Ohioans who vote by mail.” The bill “is all burden for so little benefit. Therefore, this veto is in the public interest,” he added. DeWine also praised Ohio’s elections, citing Secretary of State Frank LaRose’s comments on Ohio elections being “the gold standard nationwide.” DeWine’s other concerns included verifying the photo ID and costs incurred for the secretary of state’s office in maintaining a portal and the Board of Elections. The Ohio Association of Election Officials warned that “senior citizens, individuals living in long-term care facilities, voters with mobility challenges, and those with limited access to technology may face additional burdens that could discourage participation or prevent otherwise eligible voters from casting a ballot,” DeWine added. Stephanie Kreuz, director of sentinel strategy at Heritage Action, told the Daily Signal that the veto amounted to “betrayal.” “Gov. DeWine’s veto of HB 472 is a huge betrayal to Ohio voters who expect secure elections. Requiring absentee voters to verify their identity is common sense. By rejecting this measure, Gov. DeWine has chosen to side with radical leftists over reasonable Americans who support strong voter ID protections,” she said. “Ohio has led on election integrity, but this veto is a step back. Gov. DeWine has needlessly obstructed election reform that would help strengthen the security of Ohio’s elections for future generations. Heritage Action is grateful for the Ohio legislators who are standing with voters in making it easy to vote and hard to cheat.” A common theme among Republican leaders is disappointment. “We are disappointed by the governor’s veto of House Bill 472, despite 60 out of 65 Republican members of the Ohio House and growing public demand for stronger election safeguards, including voter ID protections,” Ohio House Speaker Matt Huffman told the Daily Signal. However, this may not be the end of the road. Huffman said leaders plan to review the governor’s concerns and evaluate next steps. “The overwhelming majority of Ohio House Republicans remain committed to protecting the integrity of Ohio’s election system,” he added. Senate President Rob McColley, who is also the Republican pick for lieutenant governor, also pointed to the popularity of voter ID. “Photo ID laws are supported by a vast majority of Ohio voters. It is disappointing the governor would oppose such a common sense election security bill when Democrat controlled states such as Virginia and Hawaii have repealed their photo ID laws,” he said in a statement. “HB 472, when combined with this fall’s Constitutional Amendment requiring photo identification to vote, would have given Ohioans the confidence to know that their election system was the most secure in the country.” Senate President Statement on Veto of Photo ID Election Security Bill https://t.co/PJccegsUq6 pic.twitter.com/PPHk6uwgA8— Ohio Senate GOP (@OhioSenateGOP) June 25, 2026 Recent polling from Honest Elections Project Action shows that voter ID is popular with likely Ohio voters, as is the specific provision requiring ID for mail-in ballots. State Sen. Jane Timken, who sponsored the resolution for the state ballot initiative that McColley referenced, issued a similar warning when speaking to the Daily Signal about voter ID laws being repealed elsewhere, including in Virginia. In May, Republican nominee for governor Vivek Ramaswamy called for enshrining Ohio’s law on voter ID in the state constitution, and the state Legislature quickly heeded that call, drafting a resolution and passing it out of both chambers weeks later. While the governor mentioned concerns for the secretary of state’s office, and even mentioned the current secretary by name, both LaRose and Robert Sprague, the Republican nominee to replace LaRose, chimed in on X to express disappointment. I’ve long been an advocate for both a strict photo ID requirement and an online absentee ballot application system, and I told the governor we could effectively implement the bill if he signed it. He chose a different path. Regardless, it’s clear that we need to continue planning…— Frank LaRose (@FrankLaRose) June 25, 2026 Sprague’s post referenced Ramaswamy, and the work a new administration can do. “My priority as Secretary of State is to run the most secure elections in Ohio history, and to that end, as Secretary, I will work with the legislature and Governor Ramaswamy to ensure that all forms of voting are secure, that fraud is prevented, and that cheaters are caught and prosecuted,” he wrote. I support photo ID for all forms of voting, and it’s disappointing that the Governor has vetoed HB 472.  Photo ID is a common sense, commonplace requirement in everyday life and the most trustworthy means of ensuring that a person is who they say they are.  The legislation would…— Robert Sprague (@RobertCSprague) June 25, 2026 Ramaswamy’s own post referenced the importance of photo ID, including for mail-in ballots, while also expressing hope in the ballot initiative for this November. “This constitutional amendment also enables Ohio lawmakers to expressly apply the photo ID requirement to all ballots, including mail-in ballots (which I would sign into law and which most Ohioans support),” he wrote. As Ramaswamy also mentioned, President Donald Trump has urged support for the ballot initiative. Requiring photo ID to vote is a common-sense measure that most Americans support, across demographic & partisan lines. Whether or not Congress passes the SAVE Act this year, Ohio voters have an opportunity to VOTE YES in November to enshrine the photo ID requirement in our state…— Vivek Ramaswamy (@VivekGRamaswamy) June 25, 2026

State Department Unveils America250 Passports at Trump’s Great American State Fair
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State Department Unveils America250 Passports at Trump’s Great American State Fair

FIRST ON THE DAILY SIGNAL—The Department of State is allowing the public to view the new America250 passports at the agency’s booth at the Great American State Fair. “Americans carry their passport as a symbol of who they are and where they come from. Now, our commemorative passport will also allow them to carry a piece of our history and our values wherever they go,” Assistant Secretary of State for Consular Affairs Mora Namdar said in a statement to the Daily Signal.   “Under President Trump and Secretary Rubio’s leadership, the State Department is proud to celebrate America’s 250th anniversary by putting the story of our nation’s founding directly in the hands of American passport holders,” Namdar said.  Americans can see the limited-edition passport and learn how to apply for one at the fair, which runs from June 25 to July 10 on the National Mall in Washington, D.C. Sneak peak here: pic.twitter.com/sx3EhXLcAt— Department of State (@StateDept) April 28, 2026 “The State Department is releasing a limited-edition commemorative passport that celebrates America’s 250th anniversary,” State Department spokesman Tommy Pigott said. “This is more than a travel document, it’s a bold, patriotic statement reflecting the enduring legacy of our nation’s first 250 years and our ongoing commitment to lead, innovate, and inspire for the next 250.”  Only 40,000 commemorative passports are available. They feature a Freedom 250 gold flag on the back cover, and a portrait of President Donald Trump framed by the text of the Declaration of Independence and the American flag, along with the president’s signature, on the inside. The interior back cover features the signers of the Declaration of Independence. Starting July 6 and continuing while supplies last, this will be the default passport issued to any American who applies in person at the Washington Passport Agency.