Two Dead, Nine Wounded—And Counting

On December 13, 2025, a gunman opened fire at Brown University during a final exam review session, killing two students and wounding nine others. The shooter used a 9mm handgun to massacre students studying for an introductory economics exam.

This was the 43rd shooting on a college or university campus in 2025 that resulted in a casualty.

Three years earlier, in June 2022, the Supreme Court handed down New York State Rifle & Pistol Association v. Bruen—a decision that fundamentally rewrote Second Amendment law and unleashed an unprecedented wave of challenges to gun safety regulations across America.

The connection isn’t speculative. It’s cause and effect.

When the Supreme Court dismantles the legal framework that allowed states and cities to protect their citizens from gun violence, people die. The bodies pile up. And the Court’s conservative majority bears direct responsibility.

What Bruen Did

In a 6-3 decision written by Justice Clarence Thomas, the Court struck down New York’s century-old law requiring applicants for concealed carry permits to show “proper cause”—a legitimate need to carry a handgun in public beyond general self-defense.

But the Court didn’t stop there. It announced a radical new framework for evaluating all gun regulations.

The Old Framework: Balancing Public Safety

Before Bruen, courts balanced the government’s legitimate public safety interests against Second Amendment rights. If a gun regulation served a compelling public interest and was narrowly tailored, it could stand.

This framework allowed cities and states to enact common-sense regulations like:

  • Requiring background checks
  • Prohibiting guns in sensitive places
  • Keeping guns away from domestic abusers
  • Limiting high-capacity magazines
  • Requiring permits for concealed carry

The New Framework: History and Tradition Only

Bruen threw out all balancing tests. Justice Thomas ruled that if a gun regulation’s “plain text” covers conduct protected by the Second Amendment, the government must prove the regulation is “consistent with the Nation’s historical tradition of firearm regulation.”

Not whether it saves lives. Not whether it serves a compelling public interest. Not whether experts believe it’s necessary for public safety.

Only whether there’s a historical analogue from the 1700s or 1800s.

This is constitutional interpretation by time machine. It makes 18th-century musket regulations the standard for evaluating 21st-century gun violence prevention laws.

The Catastrophic Results

The consequences have been exactly what gun safety advocates predicted: chaos, legal uncertainty, and a systematic dismantling of gun regulations nationwide.

An Explosion of Litigation

By 2024, the number of gun cases heard annually since Bruen rose to 680—compared with 74 in the decade prior to the decision.

That’s a 919% increase in gun litigation. Every gun safety law in America is now under assault in federal courts, with judges forced to search through colonial-era gun regulations to determine if modern public safety measures can stand.

Regulations Struck Down

Among federal laws that have been blocked from enforcement as of early 2023:

  • Domestic violence protections: Laws preventing gun ownership by those convicted of misdemeanor domestic violence
  • Restraining order prohibitions: Bans on gun possession by individuals subject to final domestic violence restraining orders
  • Felony defendant restrictions: Prohibitions on gun possession by felony defendants awaiting trial
  • Drug user prohibitions: Federal bans on gun possession by drug users
  • Machine gun regulations: At least three rulings in the past year have invalidated federal restrictions on machine guns, once considered settled law

The Court has also imperiled concealed carry laws, assault weapons bans, and a host of other gun restrictions that states enacted to protect their citizens.

The Body Count

Research shows that in states that have weakened their firearm permitting laws, the move was associated with an 11% rise in the rate of homicides with handguns.

This isn’t theoretical. When courts strike down gun safety laws, more people die. The New England Journal of Medicine warned that Bruen would have a “devastating impact on efforts to mitigate gun violence.”

They were right.

The Brown University Shooting in Context

When two students were killed and nine wounded at Brown University, they became the latest victims of a Supreme Court decision that prioritizes an absolutist interpretation of the Second Amendment over human life.

The shooter used a 9mm handgun—the kind of weapon whose regulation is now subject to the Bruen framework. Every common-sense restriction that might have prevented this tragedy—permit requirements, background check enhancements, waiting periods, restrictions on carrying in sensitive places—must now pass the “historical tradition” test.

And when those regulations fail that test and get struck down, shooters have easier access to guns. College campuses become less safe. Students studying for economics exams die.

This is the direct consequence of the Supreme Court’s gun rights extremism.

The Bruen Framework Is Unworkable

Even judges trying to apply Bruen in good faith find it impossible to implement.

Which History Counts?

Does a gun regulation need an analogue from 1791 (when the Second Amendment was ratified)? From 1868 (when the Fourteenth Amendment extended the Bill of Rights to states)? From some other period?

The Court didn’t say. Different judges have different answers. The result is chaos.

How Similar Must the Analogue Be?

Does a modern assault weapons ban need a direct 18th-century equivalent? Or is a general principle of regulating dangerous weapons enough?

Again, the Court didn’t clarify. Lower courts are left guessing, and gun regulations live or die based on individual judges’ historical interpretations.

What About New Threats?

The Founders couldn’t have imagined semi-automatic weapons, high-capacity magazines, or the epidemic of mass shootings plaguing America. The Bruen framework offers no guidance for how to address modern gun violence challenges that have no 18th-century equivalent.

This is constitutional interpretation designed to fail—and designed to strike down gun safety laws in the process.

Justice Thomas’s Selective History

The Bruen majority’s reliance on “history and tradition” is intellectually dishonest.

The decision cherry-picks historical examples that support expansive gun rights while ignoring:

  • Colonial-era restrictions on carrying guns in populated areas
  • 19th-century laws prohibiting concealed carry in many states
  • Reconstruction-era regulations limiting gun possession
  • Long-standing prohibitions on dangerous and unusual weapons

When the history doesn’t support the outcome Thomas wants, he simply ignores it or declares it “outliers.”

This isn’t originalism. It’s outcome-driven reasoning dressed up in historical costume.

The Dissents Were Right

Justice Stephen Breyer’s dissent, joined by Justices Sotomayor and Kagan, warned of the catastrophic consequences of the majority’s decision.

He noted that:

  • Gun violence is a uniquely American problem
  • The majority’s historical analysis was flawed and selective
  • The new framework would create massive uncertainty
  • States should be able to protect their citizens from gun violence

His dissent included devastating statistics about gun deaths in America—statistics the majority simply ignored in favor of musket-era history.

What This Means for Court Reform

Bruen is Exhibit C (after Loper Bright and Trump v. United States) for why the Supreme Court desperately needs reform.

Six unelected justices, appointed through a process that violated democratic norms, rewrote Second Amendment law to:

  • Dismantle century-old gun safety regulations
  • Create an unworkable legal framework
  • Ignore modern public safety concerns
  • Substitute judicial preferences for democratic choices
  • Elevate gun rights over the right not to be shot

The decision:

  • Causes deaths
  • Prevents states from protecting their citizens
  • Creates legal chaos
  • Imposes a rigid historical test with no clear answers
  • Reflects ideological commitment to gun rights extremism, not neutral legal analysis

And there’s nothing Congress, state legislatures, or voters can do to reverse it—unless we reform the Court itself.

This is why Court expansion, term limits, or jurisdiction stripping aren’t just policy preferences. They’re necessary to stop a Court that’s using its power to prevent democratically-elected governments from addressing gun violence.

The Upcoming Cases

The assault on gun safety laws isn’t over. The Supreme Court has agreed to hear multiple gun cases in its current term, including:

  • A challenge to Hawaii’s restrictions on carrying handguns on private property
  • Whether unlawful drug users can carry firearms
  • Additional challenges to concealed carry permitting systems

Each represents another opportunity for the Court’s conservative majority to further dismantle gun regulations and make America less safe.

Conclusion: A Court That Chooses Guns Over Lives

When students at Brown University sat down for an economics exam review session on December 13, 2025, they had no idea they were about to become victims of Supreme Court jurisprudence.

But that’s exactly what happened. The Court’s decision in Bruen unleashed a legal assault on gun safety laws across America, making it harder for states and cities to keep guns out of dangerous hands, to regulate concealed carry, and to protect sensitive places like schools and campuses.

Two students are dead. Nine are wounded. Forty-three campus shootings in a single year.

And the Supreme Court’s response to this carnage is to demand that gun regulations meet an 18th-century historical test rather than serve modern public safety needs.

This isn’t judicial restraint. This isn’t originalism. This isn’t neutral legal analysis.

It’s gun rights extremism, dressed up in constitutional language, imposed by six unelected judges who have decided that their interpretation of the Second Amendment matters more than the lives of students studying for exams.

The blood is on their hands. And only Court reform can stop the bleeding.