We will hear argument this morning in case 24, 12, 34, 34, United States v. Himani.

Ms. Harris.

Mr. Chief Justice, and may it please the Court, the Second Amendment does not prohibit the government from temporarily disarming habitual marijuana users while they persist in using frequently.

That tailored restriction easily fits within the historical tradition of disarming

categories of people who present a special danger of misuse. That is no license for Congress to

deem anyone dangerous. The government must show a historical analog that is relevantly similar

and why and how it restricts Second Amendment rights. Here, that's habitual drunkard

laws. Under historical vagrancy and civil commitment laws, habitual drunkards were imprisoned or

confined without specific dangerousness findings, based on judgments that habitual drunkards as a class

threaten public safety. Surety laws require them to postpone or be jailed. Like 922G3,

those restrictions reflect public safety concerns about the dangers of frequently using intoxicants,

and 922G3 is less restrictive. Habitual illegal drug users can regain their arms through their own

voluntary conduct by not using illegal drugs so often.

Upholding 922G3 would not open the door to disarming weakened beer drinkers.

Unlike alcohol, illegal drugs are illegal.

They're illegal because Congress deemed their use dangerous at any level,

and their dangers extend beyond their mind-altering effects to the risks of the illegal drug trade.

Unlike alcohol, Congress and the executive branch have made specific determinations about the dangers of illegal drugs,

and unlike alcohol, robust post-ratification history, supports disarming habitual illegal drug users, not just

frequently intoxicated users. Respondent's contrary approach that no habitual drug users can be

disarmed would invalidate 922G3 and parallel state laws, even for habitual heroin, ketamine

users, and would replace the Bruin-Rahimi framework with a discredited law-trapped and amber approach.

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