Ocean State Tactical v. Rhode Island

The First Circuit applied Bruen by holding that the historical-tradition test permits restrictions on firearm accessories even when modern use is common, finding that Rhode Island's large-capacity magazine ban can survive without requiring a direct founding-era analogue. The court reasoned that magazines, as accessories rather than arms themselves, fall within a permissible historical tradition of regulating dangerous instrumentalities, and that Bruen does not foreclose such regulations based solely on contemporary prevalence. This decision created a circuit split: while other courts have struck down similar bans by emphasizing that large-capacity magazines are in common use for lawful purposes, the First Circuit read Bruen's historical requirement more flexibly when applied to accessories. The Supreme Court's denial of certiorari allowed the disagreement to persist across circuits, leaving unsettled whether Heller's common-use protection or Bruen's historical-tradition requirement controls when analyzing magazine restrictions.