Judge John L. Sinatra Jr. in the Western District of New York granted the Firearms Policy Coalition summary judgment in Heeter v. James and permanently blocked New York's 2022 body armor purchase and sale restrictions. Those rules made first-time buys by ordinary residents a Class A misdemeanor unless they held a government-approved job, with later offenses a Class E felony, and barred sales to them. The court applied Second Amendment protection given widespread civilian ownership, the lack of similar bans in 49 states, and no post-ratification American tradition for the measure.