Tag: hit&run

Oil prices surge: Yesterday, Houthi terrorists struck two Saudi oil tankers in the Red Sea, sending oil prices up to $99 a barrel. The strikes “threatened to broaden the conflict by creating a second choke point on global shipping, in addition to the Strait of Hormuz, which Iran has effectively closed,” per The New York Times.

President Donald Trump, too, is escalating: “From this point forward, any time the Islamic Republic of Iran shoots at a ship in the Strait of Hormuz, whether it be by Missile, Rocket, Drone, or any other device or weapon, the United States will bomb and destroy ONE BRIDGE OR POWER PLANT, including those located next to, or in, the Capital City of Tehran,” he wrote on Truth Social. “Thank you for your attention to this matter!”

Technically, since the Houthis are not Iran (just backed by them), and since the Saudi strike wasn’t in the Strait of Hormuz but in the Red Sea, yesterday’s attack probably won’t warrant a U.S. bombing. But it’s a very bad sign that a second shipping corridor—the Bab al-Mandab Strait—is now threatened, as this is likely to send oil prices surging even higher.

“On Tuesday, [Trump] said U.S. military forces would likely attack Iran’s Pickaxe Mountain, the underground site where Israeli intelligence believes Iran has buried advanced nuclear-enrichment centrifuges, ‘pretty soon,'” reports The Wall Street Journal. “Trump’s threats come days after Iran launched a barrage of missile and drone attacks against U.S. bases in Jordan. Three soldiers were killed there in a strike that hit containerized housing units where the troops lived and slept. A fourth servicemember was killed last week in Iraq during a controlled detonation of unexploded ordnance from a downed Iranian drone.”

People are already souring on the war: “Half of President Donald Trump’s MAGA base thought Iran’s war was worth its economic costs in May. Now, just a little more than a third do,” reports Politico. “Additionally, 37 percent of self-identified MAGA Trump voters say the U.S. should continue its involvement only if it doesn’t increase costs, up from 29 percent who said the same in May, according to the survey, conducted by independent polling firm Public First. Nearly 1 in 5 MAGA voters believe that the U.S. should end its war in Iran, regardless of the costs.”

It looks likely to get much worse before it gets better.

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Scenes from New York: “The Commission on Government Efficiency, which the mayor formed in January, has proposed expediting the time it takes to build new street safety projects by 33%. It’s one of the five ballot questions the commission is expected to approve on Thursday that aim to speed up work by—and with—the city. The proposals will appear on voters’ ballots in November,” reports Gothamist. “Altogether, the commission settled on five proposals that it said will simplify the process to secure permits for outdoor dining, shorten the timeframe for the city’s contracting and procurement process, fast-track projects on city-owned land whether its for a street or a building, simplify the building permit process and create targets for contributions to the city’s rainy day fund to prepare for an economic downturn.”

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QUICK HITS

• “Florida’s fish and wildlife officials were caught using law-enforcement tools to probe everyday citizens who’d criticized the agency,” writes Scott Maxwell for The Orlando Sentinel.
• “The Supreme Court agreed last month to hear a case that asks a remarkable question: Can the government require a homeowner to obtain a permit before inviting friends to his house for prayer?” reports The Washington Post. “Grand v. City of University Heights centers on an Orthodox Jewish minyan—a prayer quorum consisting of at least 10 adult men—but the legal principles at stake extend well beyond one faith. In January 2021, Daniel Grand, an Orthodox Jewish homeowner in University Heights, Ohio, emailed roughly a dozen friends inviting them to his house for a Shabbat minyan. Soon afterward, a neighbor informed the city about Grand’s email, complaining and asking the mayor to ‘put a stop to this.’ Under the city’s zoning ordinance, ‘houses of worship’ require a special-use permit. Acting on the complaint, the mayor called Grand regarding what he described as an ‘urgent matter.’ Later that day, a city official ordered Grand to ‘immediately cease and desist’ using his home as a ‘place of religious assembly’ until he obtained the permit. Although Grand maintained that hosting a minyan in his home did not make it a house of worship, he complied. He canceled the gathering and applied for the permit the city demanded. What followed was a contentious zoning process.” (They should try to get my ass, because I host bible study all the time.)
• Back in 2018, the Supreme Court struck down the Professional and Amateur Sports Protection Act (PASPA) in Murphy v. NCAA, allowing states to once again legalize sports betting. So how bad is the gambling situation now? A new paper says…very bad.

The main finding: Sports betting does not merely replace other entertainment spending. Instead, it crowds out saving and increases borrowing.

For many households, the money deposited into betting apps comes directly from their financial cushion.

— Jason Kotter (@JasonKotter) July 22, 2026

Lower-income households bet a much larger share of their income. In our data, they devote roughly 2–3x as much of their income to betting as higher-income households. That gap has widened over time. pic.twitter.com/nnbO2jOH0r

— Jason Kotter (@JasonKotter) July 22, 2026

• I’m calling it here, and it brings me no pleasure to report, but I’m pretty sure it’s AOC time:

AOC leading in NH per UNH poll

AOC 22%
Pete: 21%
Mark Kelly 9%
Newsom: 8%
Bernie: 6% (have to imagine a lot of these votes would go to AOC)
Kamala: 5%https://t.co/wZWqaWGGbs pic.twitter.com/vQUKR7y5AL

— Alex Thompson (@AlexThomp) July 22, 2026

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From Alobid v. Marin, decided March 9, 2026 by Magistrate Judge Alka Sagar (C.D. Cal.), but just posted on Westlaw in the last couple of days:

Petitioner, an immigration detainee who is proceeding pro se, filed a Petition for a Writ of Habeas Corpus under 28 U.S.C. § 2241 and also filed a Motion for Leave to Proceed Under a Pseudonym.

“As a general rule, ‘the identity of the parties in any action, civil or criminal, should not be concealed except in an unusual case, where there is a need for the cloak of anonymity.'” A party’s “use of [a] fictitious name[ ] runs afoul of the public’s common law right of access to judicial proceedings, and [Fed. R. Civ. P.] 10(a)’s command that the title of every complaint ‘include the names of all the parties[.]'”

Nevertheless, the Ninth Circuit has “allowed the use of pseudonyms in exceptional cases where necessary ‘to protect a person from harassment, injury, ridicule or personal embarrassment.'” “When a party requests ‘Doe’ status, the factors to be ‘balance[d] … against the general presumption that parties’ identities are public information,’ are: ‘(1) the severity of the threatened harm; (2) the reasonableness of the anonymous party’s fears; and (3) the anonymous party’s vulnerability to such retaliation.'” The party seeking anonymity has the burden of proving it should be allowed to proceed anonymously.

Petitioner seeks to proceed anonymously because he is a convicted sex offender who believes he may face danger in his country of origin—Syria—if removed there. However, the nature of Petitioner’s criminal conviction is insufficient by itself to warrant Petitioner’s use of a pseudonym in these proceedings. See U.S. v. Stoterau (9th Cir. 2008) (“If the nature of Stoterau’s offense alone could qualify him for the use of a pseudonym, there would be no principled basis for denying pseudonymity to any defendant convicted of a similar sex offense. Such a significant broadening of the circumstances in which we have permitted pseudonymity is contrary to our long-established policy of upholding ‘the public’s common law right of access to judicial proceedings,’ and contrary to our requirement that pseudonymity be limited to the ‘unusual case.'”).

And while “‘retaliation from a foreign government is recognized by the Ninth Circuit and other district courts as a sufficient basis to proceed anonymously[,]'” Petitioner’s conclusory and unsupported assertion that he may face danger if removed to Syria is insufficient to meet his burden of establishing he should be allowed to proceed anonymously in this action.

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A new report from the Council on Criminal Justice (CCJ) suggests the national homicide rate this year will hit a historic low, continuing a downward trend that began in 2022. In January, the CCJ estimated that the 2025 homicide rate would be the lowest since at least 1900, and the latest numbers indicate that the 2026 rate will be even lower. Other kinds of crime are also down, in some cases dramatically.

That development is surely welcome news. But we should be skeptical of the explanations offered by politicians of both major parties, who habitually reduce a complex reality to evidence in favor of the policies they have long supported.

The CCJ collects crime data from 36 U.S. cities, ranging in size from Rochester (population: 200,000) to New York City (8.5 million). The homicide estimates are based on data from 30 cities that have consistently reported numbers for that crime since 2018.

After rising slightly in 2019, the average homicide rate in the CCJ sample shot up in 2020, consistent with FBI data indicating a 30 percent increase that year. The rate in the CCJ sample rose again in 2021 and fell slightly in 2022 before dropping dramatically in 2023, 2024, and 2025. According to the new report, the average homicide rate for the first half of this year was down 18 percent from the same period in 2025 and down 51 percent since the first half of 2022.

This trend goes beyond a reversion to the pre-2020 norm. “Across the sample cities,” the CCJ says, “the 2026 average homicide rate” for January through June was “about 31% lower than in 2019.”

The FBI’s national numbers tell a similar story: Homicides fell by 11.6 percent in 2023, nearly 15 percent in 2024, and 18.1 percent in 2025 (based on a preliminary estimate). According to the FBI’s preliminary data, murders during the year ending in April 2026 were down 18.2 percent from the previous 12 months.

A longer view puts these numbers in perspective. Between 1991 and 2014, according to the CCJ’s national numbers, the homicide rate fell by more than 50 percent, then rose for a few years. But as of 2019, it was still about half the 1991 peak. The estimated rate for 2025, 4 per 100,000 residents, is even lower than the 2014 number (4.4), and it seems this year’s rate will be lower still.

Looking further back, the lowest homicide rate recorded since 1900, according to the CCJ’s graph, was 4.5 per 100,000, the rate in 1957 and 1958. Those numbers come from criminologist Randolph Roth’s 2009 book American Homicide. “These data rely primarily on death registration records,” the CCJ says, “and are widely regarded as the most reliable source for estimating homicide trends prior to the modern era of national crime reporting.”

A Bureau of Justice Statistics report lists somewhat lower rates for the 1950s, as low as 4.0 in 1957. But “when the FBI went back with a new methodology in 1958,” crime analyst Jeff Asher notes, “they looked at data from 1957 again and estimated that the actual 1957 murder rate was at 4.7 per 100,000.” In other words, it looks like the current homicide rate is even lower than the historic lows recorded during the 1950s.

The CCJ also reports large declines in three other crimes based on data for the first half of each year. The carjacking and car theft rates, both of which peaked in 2023, have since fallen by 73 percent and 51 percent, respectively. The residential burglary rate in the first half of 2026 was 56 percent lower than its 2018 peak.

Comparing the first half of 2026 to the first half of 2025, the CCJ reports declines in aggravated assault (2 percent), gun assault (6 percent), larceny (6 percent), nonresidential burglary (10 percent), residential burglary (13 percent), robbery (17 percent), car theft (20 percent), and carjacking (47 percent). By contrast, sexual assault, shoplifting, and domestic violence rose by 3 percent, 4 percent, and 8 percent, respectively.

Overall, violent crime from January through June was “at or below levels in the first half of 2019,” the CCJ says. Nonviolent crime also was “generally below levels seen in the first six months of 2019.”

President Donald Trump would like to take credit for these positive trends. “Last year, the murder rate saw its single largest decline in recorded history,” he bragged during his 2026 State of the Union address. “This is the biggest decline, think of it, in recorded history. The lowest number in over 125 years.”

Inconveniently for Trump, the 2020 murder surge happened on his watch, and the rate began falling before he started his second term. In any case, it is doubtful that presidential policies have much impact on crime rates. Although Trump credits immigration enforcement, for example, his deportation campaign, contrary to the way he portrays it, is by no means carefully targeted at unauthorized residents who pose a threat to public safety.

The evidence also casts doubt on policy prescriptions that Democrats tend to offer. “Private gun ownership in America has surged in the past several years,” the CCJ notes. “Meanwhile, violent crime, particularly homicide, saw a historic rise followed by a historic decline.”

The CCJ suggests a few more plausible theories, although none is completely satisfying. “A range of crime researchers and practitioners broadly agree that there’s no single explanation for the decline” in homicides, it says. “Instead, it reflects multiple forces moving in the same direction, from prevention efforts and law enforcement strategies to broader social changes following the pandemic shock.”

Last February in USA Today, CCJ President Adam Gelb cautioned against “partisan platitudes” that offer simplistic explanations for the ongoing crime drop. “Murder and other crime are falling in cities that are governed by different political philosophies, operating under varied policing and prosecution models and facing distinct local economic conditions,” he noted. “Local policies and programs surely matter. But the striking consistency of the crime decline across the country suggests that macro-level forces are exerting enormous influence as well.”

It is plausible that the 2020 homicide spike, like the concomitant surge in drug-related deaths, had something to do with the social, economic, and educational upheaval caused by the COVID-19 pandemic and the government’s response to it. “As schools, workplaces, social programs, churches and civic institutions regained footing after COVID-19 disruption,” Gelb noted, “emotional and economic stresses eased and daily routines strengthened.”

Gelb added that “courts slowed by COVID-19 disruptions have largely resumed normal function”; that “police departments, on their heels after the protests of 2020, have reemphasized targeted enforcement strategies”; and that “communities have scaled up violence prevention efforts and prisoner reentry programs to unprecedented levels, aided in part by federal recovery funds.” He conceded that “immigration enforcement has removed dangerous offenders” but added that it has swept up “many people who pose little or no public safety risk.”

Gelb also credited “the spread of public and private surveillance cameras and license plate readers,” which he said had “deterred would-be offenders while helping police solve more cases.” He added that “the transition to digital transactions means fewer people carry cash, making them less attractive targets of a robbery.” And he suggested that “the gravitational pull of cyberspace” may be “altering social routines historically associated with street violence.”

Gelb mentioned several other possible factors, including changes in illicit drug markets, reduced alcohol consumption, less exposure to “environmental toxins” such as lead, and the “grim demographic reality” that homicides and drug overdoses may have “removed tens of thousands of high-risk people from the population.” But he noted that “researchers are still struggling to confidently explain the long-term crime drop that began in the early 1990s,” which suggests that “definitive answers about current trends will take time.”

The honest answer to the question of why crime is falling, in short, is that we don’t really know and may never be sure. As tempting as it may be for politicians, it is not safe to assume that any particular government policies have played an important role in the absence of evidence that they actually work.

The post The Homicide Rate Has Dropped to Historic Lows. Contrary to What Politicians Say, No One Really Knows Why. appeared first on Reason.com.

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7/23/1936: Justice Anthony Kennedy’s birthday.

 

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Earlier this week, lawyers for Ohio craft brewery owner John Ream, who wants to distill hard liquor at home for his own personal use but is barred from doing so by federal law, asked the U.S. Supreme Court to hear what could prove to be a major case about the reach of federal power.

The case is Ream v. U.S. Department of the Treasury. At issue is the constitutionality of the federal ban on home distilling. According to the federal government, the ban on making hard liquor at home is a legitimate exercise of the congressional power “to regulate Commerce…among the several States.” As an authority for that view, the government has cited Gonzales v. Raich (2005), in which the Supreme Court upheld the federal ban on marijuana as applied to California medical marijuana patients whose use of the plant was legal under state law and whose cultivation and consumption of the plant took place entirely within the confines of that single state. “If Congress can regulate this under the Commerce Clause,” protested Justice Clarence Thomas in dissent, “then it can regulate anything—and the Federal Government is no longer one of limited and enumerated powers.”

The petition for writ of certiorari in Ream seeks to overturn the ruling in Raich that earned Thomas’ ire. “At bottom,” argues the brief filed by Ream’s legal team, “this case asks whether the federal government must still identify an enumerated power before sending Americans to prison for what they do at home.” As for the Raich precedent, the brief urges SCOTUS to “overrule Raich or at least clarify that Congress’s commerce power does not extend to regulation of local, noncommercial conduct and that its exercise is subject to meaningful judicial scrutiny.”

A case about the legality of home distilling would be a fitting addition to the Supreme Court’s Commerce Clause jurisprudence. That’s because the line of cases that led up to Raich effectively started with 1942’s Wickard v. Filburn, another case about the home production of a federally regulated item.

Roscoe Filburn, the farmer at the center of that landmark case, grew extra wheat on his farm for his family’s personal use, either to make flour for cooking or as feed for his livestock. The problem was that Filburn’s extra wheat exceeded the maximum quota that had been set by federal regulators acting under the aegis of President Franklin Roosevelt’s New Deal. The New Dealers had established such quotas in the hopes of boosting prices by artificially restricting supplies.

Filburn’s extra wheat never entered the marketplace, nor did it cross any state lines. Still, according to the Supreme Court, that extra wheat nevertheless counted as “Commerce…among the several States” for federal regulatory purposes because Filburn’s actions exerted a “substantial economic effect” on the national wheat market by growing a product that he might otherwise have bought.

The Raich case later extended that logic to cover the intrastate cultivation and consumption of medical marijuana and its “impact” on the national black market in controlled substances.

The Ream case now asks the Supreme Court to fundamentally change its course on the Commerce Clause by overturning Raich and setting strict limits on what actually counts as a federally regulatable activity.

Time will tell if a shot of homemade whiskey will produce a different legal result than a puff of homegrown weed.

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Melbourne, Florida, Police officer William Markle has resigned after body camera video showed him and other officers mistakenly tackling and handcuffing a 15-year-old boy, leaving him with a broken arm. Police were searching for a runaway described as a white male in black clothes, but the teen they tackled was black, wearing a white shirt and jeans. Officers chased and forced him to the ground before realizing within minutes that he was not the person they were looking for. The teen suffered a broken arm during the arrest, and the officer who helped restrain him resigned about two weeks later.

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On July 17, the Third Circuit declared New Jersey’s ban on semiautomatic rifles and magazines holding over ten rounds to violate the Second Amendment.  The case is Ass’n of New Jersey Rifle and Pistol Clubs, Inc. v. Attorney General New Jersey (AJNRPC), and the 10 to 5 en banc opinion is authored by Judge Arianna J. Freeman.  This is the first circuit court decision to invalidate an “assault firearm” and magazine ban.

Some members of the court would have waited until the Supreme Court decides Viramontes/Grant (see post here), but cert was not granted on the magazine issue in those cases, plus no party sought delay.  My thought is that another good reason to decide the case is Justice Kavanaugh’s statement in the Snope cert denial that further appellate decisions will be forthcoming that “should assist this Court’s ultimate decisionmaking on the AR–15 issue.”  All of the other circuit decisions have upheld bans.

The common-use test, which derives itself from the historical tradition of the banning of “dangerous and unusual” weapons, is the focus of AJNRPC.  First, “in common use” refers to “common use for lawful purposes at the time of the modern restriction.”  Second, “lawful purposes” refers not just to self-defense, but to hunting and other lawful uses including mere possession.  Third, such use excludes a “dangerous and unusual” weapon.

Criticism of the common-use test as “a popularity poll” disregards that the Supreme Court requires this test, and “the popularity of the restricted weapons bears on [the] question” of common use for a lawful purpose.  Moreover, possession – whether keeping or bearing – is protected, not just the active use of pulling a trigger to shoot bullets in self-defense scenarios.

“Bruen‘s first step is fundamentally a textual inquiry,” but the common use inquiry is not located there.  It neither appears in the Second Amendment’s text nor is it part of the definition of “Arms,” which as Wolford noted includes “any weapon customarily used for offensive or defensive purposes.” “‘Customarily’ distinguishes items that can be used, offensively or defensively, as weapons (e.g., bricks) from weapons normally used for offensive or defensive purposes.”  So common use fits into Bruen‘s step two (the historical tradition step), as a part of “how” a modern regulation burdens the right in comparison with any relevant historical analogue.  Here, as in Heller, the “how” is a “flat ban.”  Once the plain text of the Second Amendment is implicated, the burden shifts to the state (here, New Jersey) to demonstrate a historical tradition that would warrant its modern-day law. Thus, in this arms ban case, New Jersey bears the burden to demonstrate that the semiautomatic rifles it bans are “dangerous and unusual” and, by necessity, not in common use.

Moving on to New Jersey’s ban on its listings of firearm make and models, the AJNRPC court decides that the record encompasses the same result for all semiautomatic rifles, not just the Colt AR-15.  For that, “we need not precisely define the quantity or qualities that make a weapon in common use for lawful purposes. Regardless of where those lines may be drawn, the many millions of semi-automatic rifles in circulation for lawful purposes are plainly in common use.”

Contrary to the argument that rifles are not commonly “used” in self-defense, “even if a weapon is rarely employed in incidents requiring self-defense, it may still be commonly possessed for that lawful purpose or other lawful purposes, such as hunting.”  Moreover, “Even if semi-automatic rifles are disproportionately used in some crimes, those may still represent a small fraction of those weapons’ overwhelmingly lawful use.”  Not to mention that interpersonal violence is “a general societal problem that has persisted since the 18th century,” where Bruen‘s second step is “fairly straightforward.”

Of course, the Third Circuit did not really need to engage in the level of analogical reasoning that it did, given that the Supreme Court in Heller had already engaged in the relevant historical spade work to identify the principle that arms that are “dangerous and unusual” can be banned consistent with the Second Amendment.

That’s why antebellum and Reconstruction regulations of Bowie knives, blunt weapons, and pistols as potential analogues do not work: “They are too late in time, and none enacted an outright ban on a class of weapons in common use for lawful purposes.”  No Founding-era analogue exists for such restrictions, giving little weight to later restrictions.  Third Circuit precedent, Lara v. Comm’r Pa. State Police (2025), holds that 1791 prevails over 1868 as the location of proper analogues.

The AJNRPC court next moves on to the magazine ban.  Magazines are “arms” because they feed ammunition into certain firearms, making them functional.  The label “large capacity magazine” (LCM) “is not objective: what is considered an LCM is statutorily defined.”  It used to be 15 rounds, now it is 10 rounds.  “It would defy reason for a label devised by New Jersey’s legislature to govern the reach of the Second Amendment’s text.”  As to the argument that a firearm will still operate with a ten-round magazine, “the text of the Second Amendment does not limit ‘Arms’ to the minimum equipment necessary to operate a weapon.”

In Bruen, the Supreme Court included “instruments that facilitate armed self defense” as part of the plain text definition of “arms.” Magazines obviously do so by holding ammunition and allowing the lawful gun owner to discharge a firearm in self-defense and to train for self-defense scenarios without having manually to reload over and over.

The banned magazines easily meet the common-use test.  “But the 24 million AR-15s and similar sports rifles in circulation—firearms that we have determined are in common use for lawful purposes—typically come standard with twenty- or thirty-round magazines. And there are over 100 million 30-round AR-15 magazines in circulation.”  (I would suggest there are far more.)

As for analogues, Founding-era gunpowder storage laws miss the mark – they were for fire safety, not crime control.  Nor were concealed carry regulations, which were not outright bans, relevant.

The above resolves the unconstitutionality of New Jersey’s ban on all of the listed semiautomatic rifles and on magazines.  However, the court found the record too sparse about the shotguns and pistols defined as “assault firearms,” which requires a remand to the district court for further factfinding.

Judge Paul Matey’s concurrence minces no words: “Nothing has changed in the decades since the State launched its battle against the Second Amendment and its ongoing defiance of the law.”  The terms “LCM” and “assault firearm” have no objective meanings but are “marketing materials recycled into legislation.”  Although the opinion of the court doesn’t mention features, Judge Matey explains, “There is too much evidence that all of the arms at issue—pistol grips, folding stocks, magazines containing eleven or more rounds, and the semiautomatic shotguns and pistols New Jersey lumped into the definition of ‘assault weapons’ with no real thought—are and have long been in common use for lawful purposes.”

Concurring in part, Judge Peter Phipps stresses that proper historical analogues “have the purpose of regulating people who actually or imminently misuse firearms to harm or menace others.”  However, the New Jersey prohibitions are “based on their potential for misuse, however remote, and that is broader than actual or imminent misuse.”

Judge Tamika Montgomery-Reeves concurs, but would have held the case pending the Supreme Court’s resolution of Viramontes and Grant.  Quoting the laws at issue in those cases, which could resolve AJNRPC, two definitions demonstrate (my observation) the utter irrationality of “assault weapon” bans.  Cook County includes the feature of a rifle “without a stock attached,” while Connecticut includes a rifle with a “folding or telescoping stock” attached.  Which of these contradictory features pray tell make the rifle so dangerous?

Judge Jennifer Lee Mascott concurs in part, agreeing with Judge Matey that it is unnecessary to remand the case to the district court for further factfinding.  She warns about misinterpretation of the “dangerous and unusual” concept: “But turning that designation into an antitype risks signaling to assertive State regulators that establishing a Second Amendment basis for regulation can be accomplished simply by labeling a firearm use ‘dangerous and unusual’ rather than affirmatively demonstrating historical evidence for the regulation as commanded by the Supreme Court.”

Judge Cindy Chung concurs in part and dissents in part.  She maintains that “common use” is determined at Bruen‘s step one and does not include “a type of weapon one would expect to be used for modern warfare; nor does the term embrace weapons most commonly used for criminal ends.” Instead, common use includes a weapon “an ordinary person would have at home for purposes like protecting oneself against violent interpersonal confrontation, protecting the home, and hunting.”  At step two, Judge Chung writes that “a weapon not commonly worn in public causes a terror to the people.”  She opines that a remand is necessary to apply that standard.

Judge Patty Schwartz, joined by three other judges, dissents.  The thrust of her opinion is that “the objective features of AR-15s and LCMs render them disproportionate to ‘ordinary self-defense needs’ and thus outside the scope of the Second Amendment’s protection.”  Her opinion fails to articulate what exactly those “objective features” are.  While no government in the world issues it as a standard service weapon, she asserts that the AR-15 is “an unusually dangerous tool used by the military and not an arm in common use by civilians for self-defense.”

Judge Cheryl Ann Krause dissents, complaining that the majority disregards “the democratic will of the People of New Jersey” based on “the novel theory that these weapons are ‘in common use’ because modern-day manufacturers have pumped a sufficient (yet undefined) number of them into nationwide circulation and some (again, undefined) percentage of gunowners assert their subjective intent to use them only for lawful purposes.”  Apparently, consumers buy AR-15s because manufacturers make them do so, not because such rifles and magazines are superior to the inferior ones New Jersey foists upon them.  And gunowners can’t be trusted when they explain why they purchase them.

Finally, Judge D. Brooks Smith dissents, agreeing with two other dissents and “the persuasive reasoning of Judge Wilkinson” in the Bianchi case from the Fourth Circuit.  That “persuasive reasoning” flouts the Supreme Court’s common-use test and exaggerates the power of AR-15s, without regard to the caliber of any specific rifle.

It’s been a long time coming.  The New Jersey ban was originally enacted in 1990.  I litigated a pre-Bruen challenge based on vagueness and equal protection, Coalition of New Jersey Sportsmen v. Whitman (D. N.J. 1999), aff’d (3d Cir. 2001) (no reported opinion).  We demonstrated that several “assault firearm” listings like “Avtomat Kalashnikov” (which means a full automatic in Russian) are machine gun names.  And the catchall “substantially identical” firearms alerted the public about like “other stuff like that” would.  I recall one of the judges on the Third Circuit panel asserting that “everyone knows what an assault firearm is, it’s a submachinegun with a silencer.”

The Third Circuit has now taken Second Amendment rights seriously, and the tables appear to be turning.

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Every Friday, the Russian Ministry of Justice adds new names to its dreaded Register of Foreign Agents, which identifies people and organizations who have allegedly received foreign support while engaging in political activities. This past week, the Libertarian Party of Russia (LPR) and 24 of its members were added to the list.

The registry lists the LPR as an unincorporated public association that disseminated materials of other “foreign agents” and “unreliable information” about the electoral system and policies of the Russian government. Among other allegations, the LPR has been accused of opposing the war in Ukraine and calling for violations of Russia’s territorial integrity, according to Russian news agency Interfax.

Being placed on the register means the party can no longer engage in virtually any sort of activity, notably organizing events or participating in elections.

According to a statement provided to Reason, the LPR believes that the “foreign agent” designation was triggered by the Russian government’s decision in February to name the International Alliance of Libertarian Parties (IALP) as an “undesirable organization.” Although the LPR had no connection with the IALP and issued a public statement distancing itself from the organization, it appears this decision “may have been the first signal from the authorities that libertarians should abandon their fight for the rights and freedoms of Russians,” says the party.

Adopted in 2012, Russia’s “foreign agents” law empowers the Ministry of Justice to label NGOs as “foreign agents” if they receive foreign funding and engage in political activity. Amendments adopted in 2022 broadened the law to cover media organizations and individuals, including those who do not receive foreign funding but are considered to be “under foreign influence.” The legislation, however, does not specify what qualifies as foreign influence, according to Radio Free Europe/Radio Liberty, which cited the Ministry of Justice in saying only 4 percent of the people and organizations added to the “foreign agents” register in 2025 were designated based on foreign funding.

Failing to comply with the vague requirements of Russia’s foreign agent laws (which include labeling and reporting rules) will expose LPR members to administrative or criminal liability, including fines, searches, and imprisonment. 

In a statement posted to Telegram and X, the LPR condemned the registry placement and denied receiving any foreign support or funding. It also called the move a politically motivated attack by the government to restrict speech and conduct critical of Russian President Vladimir Putin.

“As advocates of individual liberty, freedom of speech, and freedom of association, all of which are enshrined in the Constitution of the Russian Federation, we condemn any attempts to exert pressure on our fellow party members, including the imposition of absurd statuses that have no legal basis, no connection to physical reality or common sense, and that contradict the country’s fundamental law,” the party said.

Many of those the Ministry of Justice designated as “foreign agents” are prominent figures in one faction of Russia’s divided libertarian community, which currently includes two different organizations calling themselves the Libertarian Party of Russia. Among those listed are disputed LPR Chairman Marina Matsapulina and the politician and activist Mikhael Svetov, who was at the center of a party split in 2020. For individuals, the new status will make “their lives significantly more difficult,” says the LPR, as they are now required to disclose their “foreign agent” designation in many contexts, which will negatively affect their employment and educational prospects.

Since its formation in 2008, the party has made several unsuccessful attempts to gain official registration. Nevertheless, the party has run candidates in elections, at times in coalition with the leading opposition party PARNAS. In 2012 and 2014, LPR candidates won at the municipal level. The party has also organized a series of large protests and rallies, each of which drew thousands throughout the last decade.

The LPR’s open activism, though, has slowed down after authorities began widespread suppression of anti-government activity following the arrest of opposition leader Alexei Navalny. Others in the party left Russia after the country invaded Ukraine in 2022. Many party members have faced prior direct persecution by the state, including Matsapulina, who was forced to leave Russia in 2022 after being accused of “telephone terrorism” due to her participation in anti-war protests.

While the LPR has sought legal counsel to appeal the government’s decision, the overall assessment of their situation is pessimistic: “We do not expect that these restrictions and prohibitions can be overturned through the courts or by any other legal means,” says the party. As a result, Russian libertarians will likely face even greater persecution in the future as Putin’s authoritarian regime continues to tighten its grip.

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Global hunger declined for the third consecutive year, according to the Food and Agriculture Organization’s (FAO) The State of Food Security and Nutrition in the World 2026 report.

The new report estimates that 7.8 percent of the world’s people were undernourished in 2025.

The FAO report notes that less than 2.5 percent of people living in the U.S., Canada, Eastern Asia, and Europe are undernourished. Therefore, its calculations chiefly encompass the extent of hunger in developing countries in Africa, Latin America, and the rest of Asia.

Armed conflict and violence remain the primary drivers of acute food insecurity in 12 out of 13 hunger hotspots identified by the World Food Programme and the FAO.

The drop to 7.8 percent is a huge improvement since 1970, when undernourishment afflicted nearly 35 percent of people living in developing countries.

The new estimate is down from 8.1 percent in 2024 and 8.5 percent in 2023. Overall, 645 million people were still facing hunger in 2025.

While that is good news, the new estimate remains above the pre-pandemic nadir of 7.2 percent in 2017. The FAO report projects that the level of hunger will decline by 20 percent during the rest of this decade, but that 510 million people will still be undernourished in 2030. This trend falls well short of the United Nations’ sustainable development goal of zero hunger by 2030.

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