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 Wrenn v. District of Columbia, 864 F.3d 650 (D.C. Cir. 2017).

The D.C. Circuit enjoined a law requiring the showing of “good reason to fear injury” before the
granting of a concealed carry license. The court disagreed that the core of the Second Amendment
was about the home; rather, it cited Heller for its conclusion that the central component of the
Amendment is “individual self-defense.” 864 F.3d at 657. After also reviewing historical sources,
the D.C. Circuit concluded that the right to carry beyond the home for self-defense is core to the
Second Amendment, “even in densely populated areas, [and] even for those lacking special self-
defense needs.” Id. at 661.

Although the D.C. law was a licensing requirement, the D.C. Circuit again cited the reasoning
of Heller to interpret the law as a total ban against the typical and common law-abiding citizen who
has no specialized good-reason. Therefore, no determination of a level of scrutiny was necessary;
as in Heller, the law violated the “typically situated citizen’s ability to carry common arms generally.”
Id. at 667. The court concluded that “the law abiding citizen’s right to bear common arms must
enable the typical citizen to carry a gun.” Id. at 668.

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