Koons v. Platkin: What the Third Circuit Court Case Means for Concealed Carry in New Jersey

   The legal landscape surrounding concealed carry has changed dramatically in recent years. One of the most important cases affecting gun owners in New Jersey is Koons v. Platkin, a federal court case that challenged major portions of New Jersey’s concealed carry restrictions.

   If you carry a firearm, plan to carry, or simply follow Second Amendment developments, understanding this case helps explain where concealed carry rights currently stand—and where they may be headed.

Background: How We Got Here

   In 2022, the United States Supreme Court decided New York State Rifle & Pistol Association v. Bruen. This landmark decision held that Americans have a constitutional right to carry firearms in public for self-defense.

   Following the Bruen decision, New Jersey responded by passing new legislation that significantly restricted where concealed carry would be allowed. This law designated many areas as “sensitive places,” where carry would be prohibited—even for individuals with valid permits.

These locations included:

  • Public parks
  • Restaurants that serve alcohol
  • Entertainment venues
  • Casinos
  • Government buildings
  • Private property open to the public (unless explicitly allowed by the owner)
  • And many other common locations

This law made it extremely difficult for permit holders to legally carry in everyday situations.

The Lawsuit: Koons v. Platkin

   In response, several New Jersey residents and Second Amendment organizations filed a lawsuit challenging these restrictions. The case became known as Koons v. Platkin, named after the plaintiffs and New Jersey Attorney General Matthew Platkin.

The plaintiffs argued that New Jersey’s new restrictions violated the Second Amendment and were inconsistent with the Supreme Court’s decision in Bruen.

Specifically, they claimed the state was attempting to undermine the constitutional right to carry by declaring most public places off-limits.

Federal District Court Ruling

   In early 2023, a federal district court judge issued a preliminary injunction blocking enforcement of several parts of New Jersey’s law.

The court found that many of the new restrictions likely violated the Second Amendment because the state could not show sufficient historical precedent for banning carry in such a wide range of locations.

This was a significant development, as it temporarily restored carry rights in many locations while the case continued.

Third Circuit Court of Appeals Involvement

   The State of New Jersey appealed the district court’s decision to the United States Court of Appeals for the Third Circuit.

The Third Circuit reviewed the case and issued rulings affecting which parts of the law could be enforced while litigation continued.

As of now, the legal situation remains complex, with some restrictions allowed and others blocked pending further review.

This means concealed carry laws in New Jersey continue to evolve as the courts work toward a final resolution.

Why This Case Matters

The outcome of Koons v. Platkin has major implications for gun owners, particularly in New Jersey and potentially across the Third Circuit, which includes:

  • New Jersey
  • Pennsylvania
  • Delaware
  • U.S. Virgin Islands

The case could shape:

  • Where concealed carry is allowed
  • How states define “sensitive places”
  • The limits of state authority to regulate carry
  • Future Second Amendment cases nationwide

The Bigger Picture: Post-Bruen Legal Challenges

   Following the Supreme Court’s Bruen decision, multiple states enacted new restrictions that have faced legal challenges similar to Koons v. Platkin.

Courts across the country are now determining how far states can go in regulating concealed carry while still respecting constitutional protections.

   These decisions will likely continue to shape concealed carry laws for years to come.

What This Means for Responsible Gun Owners

   For permit holders, the key takeaway is that concealed carry laws are actively evolving.

It’s important to:

  • Stay informed about current laws in your state
  • Follow all applicable regulations
  • Use proper equipment designed for safe and secure carry
  • Prioritize safety, training, and responsibility

Responsible carry includes not only understanding your rights—but also your legal obligations.

717 Holsters Commitment to Responsible Carry

   At 717 Holsters, we support responsible firearm ownership and lawful concealed carry.

Our holsters are designed to provide:

  • Secure retention
  • Reliable concealment
  • Comfortable everyday carry
  • Durable, American-made craftsmanship

We believe quality equipment plays an important role in safe and responsible carry.

Final Thoughts

   Koons v. Platkin represents one of the most important ongoing Second Amendment cases affecting New Jersey and the Third Circuit.

While the final outcome remains to be seen, the case highlights the continuing legal and constitutional discussions surrounding concealed carry rights in the United States.

Staying informed is one of the most important things responsible gun owners can do.

Back to blog