We will hear argument first this morning in case 24, 1046, Wolford v. Lopez.

Mr. Beck?

Mr. Chief Justice, may I please the Court,

Bruenholds Second Amendment protects the right to publicly carry firearms.

By banning people from carrying firearms on private property that is open to the public,

unless they first obtain affirmative permission, Hawaii has run roughshod over that constitutional right.

The presumptive ban clearly implates the Second Amendment.

It's plain tax because it regulates arms-bearing conduct.

As such, the burden is on Hawaii to justify the presumptive ban with

relevantly similar historical analogs reflecting a national historical tradition of firearms

regulation. Hawaii comes nowhere close to carrying the burden. Its presumptive ban defies a

national tradition of allowing people to carry on to private property open to the public

unless the owner objects.

Hawaii's threshold position that this Court should adopt a state-by-state community standard

lacks support in this Court's precedent.

And Hawaii's argument the laws of the Kingdom of Hawaii should determine petitioner's

Second Amendment rights is completely without merit.

The presumptive ban is

inconsistent with our national historical tradition of firearms regulation. Hawaii attempts to show

a national tradition by relying on black codes expressly passed to distribute against African

Americans in anti-poaching laws. These types of laws are nowhere near, relevantly similar, because nothing in our

nation's historical tradition begins to support Hawaii's effort to thwart the excise of a fundamental

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