U.S. Court of Appeals for the First Circuit

Recchia v. Campbell

July 21, 2026

Summary

The court affirmed dismissal of the plaintiffs' facial constitutional challenge to Massachusetts's restrictions on assault-style firearms. The Second Amendment claim was foreclosed by binding circuit precedent, while the dormant Commerce Clause claim failed because the plaintiffs neither alleged discrimination favoring in-state interests nor plausibly alleged a substantial burden on interstate commerce. The Equal Protection claim failed because the challenged law burdened neither a fundamental right nor a suspect class and rationally regulated firearm sales within Massachusetts.