Wolford v. Lopez · ¶122

That custom continued until very recently. Prior to this Court’s decision in Bruen, Hawaii issued concealed-carry permits only in “exceptional case[s],” which required “an applicant [to] sho[w] reason to fear injury to the applicant’s person or property.” Haw. Rev. Stat. §134–9(a) (2011). The result? Hawaiians have rarely carried (or encountered others carrying) guns.

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