Comm2A Brings Gould v. Morgan to SCOTUS, Another “Justifiable Need” for Guns Case

Justifiable Need
Justifiable Need

Massachusetts – -( This week, Comm2A filed a petition for Writ of Certiorari with the United States Supreme Court in Gould v. Morgan. Originally filed in February of 2014, Gould is a Second Amendment challenge to licensing policies in Brookline and Boston which require applicants to demonstrate a ‘proper purpose’ for carrying a firearm. If the court grants certiorari review the case will likely be heard during the October Term 2019.

Gould v. Morgan represents the first time that Comm2A has brought a case all the way to the nation’s highest court.

The Questions Present Are:

  • Whether the Second Amendment protects the right to carry a firearm outside the home for self-defense.
  • Whether the government may deny categorically the exercise of the right to carry a firearm outside the home to typical law-abiding citizens by conditioning the exercise of the right on a showing of a special need to carry a firearm.

Gould is the third carry petition filed with the court during the current term. The high court granted cert in New York State Rifle & Pistol Association v. City of New York a limited scope case that challenges a New York City regulation that prohibits holders of a premise license from transporting their firearms outside of the city. Oral argument in this case will take place during the October Term 2019. An amicus curiae brief from Comm2A is forthcoming.

In December a cert petition was filed in Rogers v. Grewal, a challenge to the New Jersey law requiring applicants for a Handgun Carry Permit to demonstrate a “justifiable need to carry a handgun”. Respondent New Jersey has until April 19th 2019 to file a response. The questions presented in Rogers are identical to those presented in Gould.

Commonwealth Second Amendment (Comm2A)ABOUT Comm2A

Comm2A is a not-for-profit charitable organization as defined under Section 501(c)(3) of the Internal Revenue code. Donations made to Comm2A are fully tax deductible as charitable contributions for US federal income tax purposes. All donations are greatly appreciated and will be used to support a variety of legal and educational projects. Visit:

Most Voted
Newest Oldest
Inline Feedbacks
View all comments

Rights are only valid if those allowing you to have them don’t take them away. You want rights, you actually have to stand up for them. Freedom is not a Right, it is something you have to take back from those trying to keep it from you. We dishonor those that fought for our freedom if we do nothing while those rights are being taking away.

If you want to keep your rights and even get some back, get out and work for a political candidate that supports your ‘similar’ views, get involved.


brookline & ma: BIOOYFA


correction: BIOOYMFA

J. Higby

Special need? Just show a poster of the MS-13 gangbangers crossing the border, en masse. Case closed.


A Constitutional Right does not require expounding a need to anyone, especially to public servants, prior to the exercise thereof.

Moreover, the exercise of a Constitutional Right cannot be converted into a crime!

R L Diehl

BINGO! We have the right to ‘keep and bear’ without infringement. How does that just get totally ignored?

Wild Bill

@RLDiehl, Woodrow Wilson wanted his way but realized that the Constitution is the impediment to governmental action that can not be gotten around, over, under or through. His conclusion was to ignore it, and he taught others. Ignoring the Constitution is now an institutionalized conspiracy. Drain the swamp.

Charles Moore

I think that “Ignoring the Constitution” is the title for a series of courses at many major universities across the county. Used books for the course can be had at very cheap prices, as most of the students that had them were too lazy to even color any of the pictures.


How does that get totally ignored?
People fear what they do not understand… that is basic human nature. The problem is that we have been woefully poor as a nation (especially in our schools) in educating our citizens about our Constitution. We’ve even allowed Schools to turn into Leftist indoctrination factories.
…Therefore, the public today (ESPECIALLY in populous blue coastal metropoli) have had no exposure to firearms OR the meaning of the 2nd Amendment — and since they do not understand either, they fear both!


The list of reasons to carry out side your home, is the same list of all people robbed or killed outside their homes in the past. If there was an exhaustive list of the individuals that were going to be robbed while away from their homes then the prosecution needs to be forth coming and submit it. If they can not submit a list of all future victims to the court, then they can not sufficiently deny anyone’s need for future protection.


It is a bill of Rights not a bill of Needs

n r ringlee

My proper purpose is this: because I say so.


fu & your “proper purpose” – commie a**holes