Safe storage laws promote responsible gun-owning practices by requiring gun owners to keep their firearms out of the reach of others, such as children or prohibited persons, who could use the weapon to deadly effect. These laws help prevent tragedies due to unintentional discharges, suicide, and gun theft by creating an environment helping ensure firearms are only used by the their rightful owners.


Safe storage laws require people to responsibly store their firearms and ammunition when they are not in use in order to prevent minors, thieves, and other unauthorized users from gaining unsupervised access to deadly weapons. Whereas Child Access Prevention Laws allow law enforcement to hold adults accountable after the fact for irresponsibly storing firearms around children, safe storage laws prescribe affirmative safety requirements. These laws typically require that guns be stored in a locked container or gun safe or disabled with a gun lock1 when not in use. These laws are necessary to shape responsible storage practices, prevent firearm theft, and reduce firearm suicides, accidents, and homicides by children and unauthorized users. For more information about children and firearms, see our summary on Child Access Prevention.

Unsafely stored firearms cause major public health and safety problems in the United States

Researchers estimate that more than half a million firearms are lost or stolen from private residences each year.2 These unsecured guns are a major source of black market weapons and are a significant threat to public safety. Safe firearm storage laws help prevent burglars and other dangerous people from gaining unauthorized access to firearms. For more information, see our summary on Reporting Lost & Stolen Firearms.

Safe storage laws also prescribe responsible storage practices to keep firearms inaccessible to children and teens. A 2018 study found that 4.6 million minors in the US live in homes with at least one loaded, unlocked firearm.3 Another study of firearm storage patterns in the US found that “[o]f the homes with children and firearms, 55% were reported to have one or more firearms in an unlocked place,” and 43% reported keeping guns without a trigger lock in an unlocked place.4 Alarmingly, a large-scale study found that this number includes a large number of minors with major risk factors for suicide: Among teens living in homes with guns, the study found that roughly 40% of those who had serious risk factors for suicide (such as recent depression or suicidal thoughts), and roughly 40% who had attempted suicide in the past year reported having “easy access” to the guns in their home.5 In addition, 73% of children under age 10 living in homes with guns reported knowing the location of their parents’ firearms.6

When minors have unsupervised access to operable firearms, tragedies result far too often. Minors living in homes with unsecured guns are at especially high risk of suicide and accidental firearm injury.7 Between 2004 and 2014, over 6,000 minors intentionally shot themselves.8 The vast majority of them used guns owned by someone in their home.9

Every year, firearms also cause thousands of unintentional deaths and injuries. Recent research on unintentional shootings has found that such accidents “occurred roughly twice as often as the records indicate, because of idiosyncrasies in how such deaths are classified by the authorities.”10 Even these lower reported numbers indicate that from 2005 to 2014, roughly 20,000 American minors were killed or seriously injured in accidental shootings; the majority of those killed in these tragic accidents were aged 12 or younger.11

Too often, minors have also used their families’ unsecured firearms to intentionally perpetrate violence against others. In the three years after the Sandy Hook Elementary School shooting, there were at least 84 school shootings in K-12 schools in the US.12 The majority of these shootings were perpetrated by minors.13 A report published by the US Secret Service and the Dept. of Education found that in 65% of school shootings covered by the study, the shooter used a gun obtained from his or her own home or from the home of a relative.14 The Department of Education also reported that during the 2009-10 school year, one in every 30 K-12 schools took serious disciplinary action against at least one student for use or possession of a firearm on school property.15

Safe Storage Laws Save Lives

The US General Accounting Office has estimated that 31% of accidental deaths caused by firearms could be prevented by the addition of two devices: a child-proof safety lock and a “loading indicator,” a safety device that indicates whether a firearm is loaded and still has a round of ammunition in its chamber.16

Researchers have also shown that laws requiring use of gun locks are effective at preventing suicides. Massachusetts is the only state in the nation that requires that firearms be stored with a locking device in place in all cases when they are not in use. Massachusetts’ law requires individuals to securely store firearms in a locked container or equipped with a tamper-resistant mechanical lock or other gun safety device. This law is effective. Guns are used in just 9% of youth suicides in Massachusetts, compared to 39% of youth suicides nationally, and the overall suicide death rate among youth in Massachusetts is 35% below the national average.17 California, Connecticut, and New York also require that guns must be securely stored around people who cannot legally possess them, which may include children. California also requires that all firearms sold in the state, including handguns and long guns sold by any party, must include a gun lock or other approved gun safety device; Connecticut, Massachusetts, and New Jersey require that gun locks must be included in the sale of a handgun by any party. Along with New York, these four states have the lowest rates of youth suicide in the nation. States with a law in place that required handguns to be locked at least in certain circumstances have 40% fewer suicides per capita and 68% fewer firearm suicides per capita than states without these laws.18 This correlation is unchanged even after controlling for the effects of poverty, population density, age, education, and race/ethnicity.19

By ensuring that firearms are safely secured from unauthorized users, such as a firearm owner’s children or severely mentally ill individuals who could not themselves legally obtain a firearm, these laws help prevent vulnerable individuals from accessing firearms in moments of crisis.

Americans strongly support laws requiring the safe storage of firearms. A national survey conducted in January 2013 found that 67.2% of respondents support laws requiring gun owners to lock up any guns in the home when not in use to prevent handling by children or teenagers without adult supervision.20

Summary of Federal Law

In October 2005, as part of the Protection of Lawful Commerce in Arms Act, Congress passed and the President signed into law legislation making it unlawful for any licensed importer, manufacturer or dealer to sell or transfer any handgun unless the transferee is provided with a secure gun storage or safety device.21 The law includes various exceptions, including transfers to other federal firearms licensees, law enforcement officers, and federal, state or local agencies.22 The legislation does not apply to transfers by private sellers, and does not require that transferees use the device.23

There are no current federal standards for locking devices.24 On January 16, 2013, President Obama signed a series of executive orders to address gun violence and school safety in the wake of the Newtown, Connecticut school massacre in December 2012. One of these orders calls for the Consumer Product Safety Commission to review the effectiveness of gun locks and gun safes, including existing voluntary industry standards, and take any steps that may be warranted to improve the standards. As stated by the President: “We also need to make sure that gun locks and gun safes work as intended. Several gun locks have been subject to recall due to their failure to function properly; that is not acceptable.”25

Summary of State Law

Eleven states have laws concerning firearm locking devices. Massachusetts is the only state that generally requires that all firearms be stored with a lock in place; California, Connecticut, and New York impose this requirement in certain situations. Other state laws regarding locking devices are similar to the federal law, in that they require locking devices to accompany certain guns manufactured, sold, or transferred. Five of the eleven states also set standards for the design of locking devices or require them to be approved by a state agency for effectiveness.

State Firearms Must Be Kept Locked Locks Must Accompany Dealer Sales Locks Must Accompany Private Sales Locks Must Meet Standards or Be Approved
California26 Sometimes Yes Yes Yes
Connecticut27 Sometimes Handguns only Handguns only Yes
Illinois28 Handguns only
Maryland29 Handguns only Yes
Massachusetts30 Yes Handguns and assault weapons only31 Handguns and assault weapons only Yes
Michigan32 Yes
New Jersey33 Handguns only Handguns only
New York34 Sometimes Yes Yes
Ohio35 Offer only
Pennsylvania36 Handguns only
Rhode Island37 Handguns only

Description of State Laws Regarding the Safe Storage of Firearms

For citations to these laws, please see the table above.

States Requiring that All Firearms be Stored with a Locking Device in Place

Massachusetts is the only state that requires that all firearms be stored with a locking device in place when the firearms are not in use. The state bars storing or keeping any firearm unless it is secured in a locked container or equipped with a tamper-resistant mechanical lock or other safety device. This requirement does not apply to any firearm “carried by or under the control of the owner or other lawfully authorized user.”

The District of Columbia has established a strong, yet non-binding policy that each firearm registrant should keep any firearm in his or her possession unloaded and either disassembled or secured by a trigger lock, gun safe, locked box, or other secure device.38

States Requiring that Firearms be Stored with a Locking Device in Place if the Person Resides with a Prohibited Person

Three states require firearms to be stored with a locking device in place if the person resides with someone who is ineligible to possess firearms. New York enacted a law in 2013 that requires a firearm owner to keep his or her firearm locked if he or she lives with a convicted felon, a domestic abuser, or a person with a federally prohibitive mental health history. California enacted a similar law that requires a firearm owner to keep his or her firearm in a locked container or secured with a locking device if he or she lives with a person prohibited under state or federal law from possessing a firearm. Connecticut’s law is also similar, but it only applies to loaded firearms.

A number of states require safe storage of firearms in circumstances where children are likely to access the firearms. These laws are discussed in our summary on Child Access Prevention.

States Requiring Locking Devices with All Firearms Manufactured, Sold or Transferred in the State

California has the most comprehensive laws with respect to firearm locking devices. In California, all firearms manufactured in the state, or sold or transferred by a state licensed dealer (including private transfers conducted through licensed dealers) must include or be accompanied by a firearm safety device approved by the state Department of Justice. A firearm safety device is defined as “a device other than a gun safe that locks and is designed to prevent children and other unauthorized users from firing a firearm. The device may be installed on a firearm, be incorporated into the design of the firearm, or prevent access to the firearm.” Sales and transfers by licensed dealers are exempt if the purchaser provides proof of ownership of an approved safety device or gun safe meeting state standards.

In Massachusetts, any handgun or assault weapon sold without a safety device designed to prevent discharge by unauthorized users is considered to be defective. The sale of such a weapon constitutes a breach of warranty and an unfair or deceptive trade act or practice.39

States Requiring Locking Devices on All Firearms Transferred by Licensed Dealers

New York prohibits retail sales of firearms without a locking device, which may be an external device or integrated in the design of the firearm. Michigan prohibits licensed dealers from selling a firearm unless the sale includes a trigger lock or gun case or other storage container. This does not apply if the purchaser presents to the dealer at the time of sale of the firearm a trigger lock, gun case or storage container, together with a copy of the receipt for the trigger lock or storage container. In Ohio, at the time of sale of any firearm, a dealer must offer to sell the purchaser a trigger lock, gun lock or gun locking device appropriate for that firearm.

States Requiring Locking Devices with Handgun Sales

Connecticut and New Jersey require locking devices on all handguns sold in the state. The laws in four other states (Illinois, Maryland, Pennsylvania, and Rhode Island) are similar to federal law, and require trigger locks only on all handguns sold by retail dealers. New Jersey prohibits the delivery of a handgun to any person unless it is accompanied by a trigger lock or locked gun case, gun box, container or other secure facility. Similarly, in Connecticut, all handguns sold or transferred (other than at wholesale) must be equipped with a trigger lock or other locking device.

In Illinois, the device may be an external safety device or an integrated mechanical safety device. Maryland’s statute provides that handguns manufactured after Jan. 1, 2003, must have an integrated mechanical safety device. (Both Illinois and Maryland define “integrated mechanical safety device” as a disabling or locking device that is built into the handgun and designed to prevent the handgun from being discharged unless the device has been deactivated). In Rhode Island, licensed retail dealers may not deliver any handgun to a purchaser without providing a trigger lock or other safety device designed to prevent unauthorized users from operating the handgun. In Pennsylvania, sales of handguns by licensed dealers must be accompanied by a locking device. “Locking device” is defined as either: 1) a device that, when installed on a firearm, is designed to prevent the firearm from being operated without first deactivating the device; or 2) a device that is incorporated into the design of a firearm and designed to prevent the operation of the firearm by anyone not having access to the device.

States that Set Standards for Locking Devices or Maintain a Roster of Approved Devices

California has the most comprehensive standards for locking devices. Through rules promulgated by the Attorney General, California requires testing of and sets standards for firearm locking devices. Locking devices are tested by certified laboratories, and those found to meet standards are listed in a roster of approved devices that may be sold in the state. The state may randomly retest samples to ensure continued compliance. California prohibits any person from commercially selling any firearm safety device that is not listed on the roster.

Maryland and Massachusetts maintain rosters of approved locking devices. In Maryland, the list of “Approved Integrated Mechanical Safety Devices” is issued by the state Handgun Roster Board. In Massachusetts, safety devices must be approved by the Colonel of the Department of State Police.

The New York State Police has also promulgated general standards for locking devices, requiring, among other things, that the device must: 1) open only by either a numeric combination, key, magnetic key or electronic key; and 2) be constructed with such quality of workmanship and material that it may not be pried open easily, removed or otherwise defeated by the use of “common household tools.” Similarly, Connecticut law requires that locking devices be constructed of material strong enough to prevent them from being easily disabled, and must be accessible by key or electronic or mechanical accessory specific to the locking device to prevent unauthorized removal.

Selected Local Laws

New York City

New York City requires any lawful owner or custodian of a firearm to render his or her weapon inoperable by use of a safety locking device while the weapon is out of his or her immediate possession or control.40 New York City also requires the inclusion of a safety locking device with the transfer of a firearm. The city prohibits the transfer of any firearm without a “safety locking device,” defined as “a design adaptation or attachable accessory that will prevent the use of the weapon by an unauthorized user.”41 In addition, no person may obtain a firearm without purchasing or obtaining a safety locking device at the same time.

In 2012, a New York trial court upheld the City’s ordinance42 on the basis that the law was not a complete ban on handgun possession in the home as was the case in Heller v. District of Columbia,43 the seminal case in which the United States Supreme Court held that law abiding, responsible citizens have a right to possess a handgun in the home for self-defense. Because individuals could easily and quickly enable their guns for self-defense, the court found that the ordinance did not violate the Second Amendment.44

San Francisco, California

San Francisco prohibits any person from keeping a handgun within a residence unless the handgun is stored in a locked container or disabled with a trigger lock unless the handgun is carried on the person.45 Unlike the laws of some other jurisdictions, San Francisco does not exempt a person who keeps his or her handgun within his or her immediate control from the requirements of the statute.

The National Rifle Association and individual plaintiffs sued in federal court to overturn San Francisco’s safe storage law on Second Amendment grounds.46 The law was upheld by both the district court and the Ninth Circuit Court of Appeals. In upholding the law, the Ninth Circuit recognized that unlike the District of Columbia law at issue in Heller v. District of Columbia,47 the San Francisco ordinance does not prohibit a person from carrying a loaded handgun while in his or her home. The Court also held that a safely stored gun can be accessed from a safe or enabled within a few seconds. The increased time it takes for a gun owner to access his or her gun is negligible, therefore, it does not place an impermissible burden on the Second Amendment rights of gun owners.48

Sunnyvale, California

The City of Sunnyvale prohibits a person from keeping a firearm in any residence owned or controlled by that person unless the firearm is stored in a locked container, or the firearm is disabled with a trigger lock, when it is not carried on the person or in his or her immediate control and possession.49 The ordinance requires a person who choses to use a trigger lock to use one that is listed on the California Department of Justice’s list of approved firearms safety devices.

Albany, New York

In September, 2015, the City of Albany enacted an ordinance prohibiting any person who owns or is a custodian of a firearm from storing or leaving out of his or her possession and control, a firearm that is not disabled by a locking mechanism or securely locked in a safe storage depository.50 The depository must be incapable of being opened without the key, combination or other unlocking mechanism and capable of preventing an unauthorized person from obtaining access to and possession of the firearm contained therein.51

Key Legislative Elements

The features listed below are intended to provide a framework from which policy options may be considered. A jurisdiction considering new legislation should consult with counsel.

  • All firearms are required to be kept disabled with a locking device except when an authorized user is carrying it on his or her person or has the firearm under his or her immediate control (Massachusetts, New York City).
  • Locking devices are required on all firearms manufactured, sold or transferred in the jurisdiction (California).
  • Standards are set for locking devices (California, Connecticut, New York).
  • Locking devices are tested and approved by a certified independent lab before they may be sold in the jurisdiction (California).
  • A roster is maintained of approved locking devices (California, Massachusetts; Maryland maintains a roster of approved locking devices, but only for handguns).


  1. Firearm locking devices include a wide range of devices designed to keep unauthorized users from gaining access to guns. These mechanisms include: 1) internal locks, which are normally mounted in the grip of the gun, and either lock the manual thumb safety into place or internally secure the hammer; and 2) external trigger locks, the most common of which cover the trigger mechanism on either side with two metal or plastic pieces that clamp around the trigger guard and completely cover the trigger. ⤴︎
  2. ATF, Following the Gun: Enforcing Federal Laws Against Firearms Traffickers  (Jun. 2000): xi, 41, ⤴︎
  3. Deborah Azrael,  Joanna Cohen, Carmel Salhi, and Matthew Miller, “Firearm Storage in Gun-owning Households with Children: Results of a 2015 National Survey.” Journal of Urban Health (2018): 1-10. ⤴︎
  4. Mark A. Schuster et al., “Firearm Storage Patterns in U.S. Homes with Children,” 90 Am. J. Pub. Health (Apr. 2000): 588, 590, ⤴︎
  5. Joseph A. Simonetti, et al, “Psychiatric Comorbidity, Suicidality, and In-Home Firearm Access Among a Nationally Representative Sample of Adolescents,” Journal of the American Medical Association Psychiatry, Vol. 72(2) (2015): 152-59, ⤴︎
  6. Frances Baxley & Matthew Miller, “Parental Misperceptions About Children and Firearms,” 160 Archives of Pediatric & Adolescent Med. (2006): 542, 544. ⤴︎
  7. See, e.g., A. Anglemyer, et al, “The accessibility of firearms and risk for suicide and homicide victimization among household members: a systematic review and meta-analysis,” Annals of Internal Medicine, Vol. 160(2) (2014): 101-10; David C. Grossman, et al., “Gun Storage Practices and Risk of Youth Suicide and Unintentional Firearm Injuries,” Journal of the American Medical Association, Vol. 293 (Feb. 2005): 707, 711-13,; ED Shenassa, et al, “Safer storage of firearms at home and risk of suicide: a study of protective factors in a nationally representative sample,” Journal of Epidemiology and Community Health, Vol. 58(10) (2004): 841-48; Matthew Miller & David Hemenway, “The Relationship Between Firearms and Suicide: A Review of the Literature,” 4 Aggression & Violent Behavior (1999): 59, 62-65; DA Brent, et al, “Firearms and adolescent suicide. A community case-control study,” American Journal of Disabled Children, Vol. 147(10) (1993): 1066-71,; AL Kellermann, et al, “Suicide in the home in relation to gun ownership,” New England Journal of Medicine, Vol. 327(7) (1992): 467-72. ⤴︎
  8. According to CDC Fatal Injury and Non-Fatal Injury Reports data. This includes 4,557 minors who died from firearm suicides and 1,621 who were hospitalized or treated in emergency rooms for intentional, self-inflicted gunshot injuries over this period. ⤴︎
  9. Renee Johnson, et al, “Who are the owners of firearms used in adolescent suicides?,” Suicide and Life Threatening Behavior, Vol. 40(6) (Dec. 2010): 609–11,; David C. Grossman, et al, “Self-inflicted & Unintentional Firearm Injuries Among Children & Adolescents: The Source of the Firearm,” 153 Archives of Pediatric & Adolescent Medicine (Aug. 1999): 875, ⤴︎
  10. See Michael Luo & Mike McIntire, “Children and Guns: The Hidden Toll,” N.Y. Times, Sept. 28, 2013, ⤴︎
  11. Based on the most recent available fatal and non-fatal firearm injury data collected by the Centers for Disease Control and Prevention (“CDC”). From 2005 to 2014, 18,373 minors in the US were hospitalized for unintentional, non-fatal gunshot injuries. An additional 968 minors died from unintentional gunshot injuries over this period. 485 of these victims were aged 0-12 at the time of death. “Injury Prevention & Control: Data and Statistics,” Centers for Disease Control and Prevention, Accessed June 18, 2018, and ⤴︎
  12. Everytown for Gun Safety, Analysis of School Shootings (Dec. 31, 2015), ⤴︎
  13. Id. This is among those incidents where the age of the shooter and the source of the firearm could be determined. ⤴︎
  14. U.S. Secret Service & U.S. Dep’t of Education, The Final Report & Findings of the Safe School Initiative – Implications for the Prevention of School Attacks in the United States (July 2004): 27, ⤴︎
  15. Robers, S., et al, Indicators of School Crime and Safety: 2014 (National Center for Education Statistics, U.S. Department of Education, and Bureau of Justice Statistics, Office of Justice Programs, U.S. Department of Justice, 2015), ⤴︎
  16. United States General Accounting Office, Accidental Shootings: Many Deaths and Injuries Caused by Firearms Could Be Prevented (March 1991), 17, ⤴︎
  17. Based on CDC data for 2004-2014 among minors aged 10-17. ⤴︎
  18. Michael D. Anestis and Joye C. Anestis, “Suicide Rates and State Laws Regulating Access and Exposure to Handguns,” American Journal of Public Health 105, no. 10 (2015): 2049–2058. ⤴︎
  19. Id. ⤴︎
  20. Colleen L. Barry et al., “Perspective: After Newtown — Public Opinion on Gun Policy and Mental Illness, 368 New Eng. J. Med. (March 21, 2013): 1077-1081, ⤴︎
  21. 18 U.S.C. § 922(z)(1). A “secure gun storage or safety device” is defined under 18 U.S.C. § 921(a)(34) as: (A) a device that, when installed on a firearm, is designed to prevent the firearm from being operated without first deactivating the device; (B) a device incorporated into the design of the firearm that is designed to prevent the operation of the firearm by anyone not having access to the device; or (C) a safe, gun safe, gun case, lock box, or other device that is designed to be or can be used to store a firearm and that is designed to be unlocked only by means of a key, a combination, or other similar means. ⤴︎
  22. 18 U.S.C. § 922(z)(2). ⤴︎
  23. The law also immunizes any person who is in lawful possession and control of a handgun and who uses a secure gun storage or safety device with the handgun, from a “qualified civil liability action.” 18 U.S.C. § 922(z)(3)(A). “Qualified civil liability action” is defined as a civil action for damages resulting from the criminal or unlawful misuse of a handgun by a third party if: 1) the handgun was accessed by another person who did not have the authorization of the lawful possessor; and 2) at the time the handgun was accessed it had been made inoperable by the use of a secure gun storage or safety device. 18 U.S.C. § 922(z)(3)(C). ⤴︎
  24. The federal Consumer Product Safety Act, which imposes health and safety standards on consumer products, exempts firearms and ammunition from its requirements. 15 U.S.C. § 2052(a)(5)(E), referencing 26 U.S.C. § 4181 et seq. Therefore, the Consumer Product Safety Commission (CPSC) has no authority to mandate that firearms include locking devices. Locking devices themselves, however, are not exempt, and therefore the CPSC has the authority to adopt national safety standards for locking devices. ⤴︎
  25. The White House, Now is the Time: The President’s Plan to Protect Our Children and Our Communities by Reducing Gun Violence (Jan. 16, 2013): 10, ⤴︎
  26. Cal. Penal Code §§ 16540, 16610, 16870, 23635-23690, 31910(a)(1), (b)(1), 25135, 32000; Cal. Code Regs. tit. 11, §§ 4093–99. ⤴︎
  27. Conn. Gen. Stat. §§ 29-33(d), 29-37b, 29-37i. ⤴︎
  28. 720 Ill. Comp. Stat. 5/24-9.5. ⤴︎
  29. Md. Code Ann., Pub. Safety § 5-132. ⤴︎
  30. Mass. Gen. Laws ch. 140, §§ 131K, 131L(a); 940 Mass. Code Regs. 16.02, 16.04 – 16.07. ⤴︎
  31. An entity responsible for the manufacture, importation or sale as an inventory item or consumer good of these weapons that does not include or incorporate a locking device shall be individually and jointly liable to any person who sustains personal injury or property damage resulting from the failure to include or incorporate such a device. Mass. Gen. Laws ch. 140, §§ 131K. ⤴︎
  32. Mich. Comp. Laws § 28.435. ⤴︎
  33. N.J. Stat. Ann. § 2C:58-2a(5)(d), (e). ⤴︎
  34. N.Y. Gen. Bus. Law § 396-ee; New York Penal Law § 265.45; N.Y. Comp. Codes R. & Regs. tit. 9, § 471.2. ⤴︎
  35. Ohio Rev. Code Ann. § 2923.25. ⤴︎
  36. 18 Pa. Cons. Stat. § 6142. ⤴︎
  37. R.I. Gen. Laws § 11-47-60.3. ⤴︎
  38. D.C. Code Ann. § 7-2507.02(a). ⤴︎
  39. California and Massachusetts also require internal safety features on handguns, including chamber load indicators and/or magazine safety disconnect mechanisms. These provisions are discussed in our summary on Design Safety Standards. ⤴︎
  40. New York, N.Y., Admin. Code §§ 10-311, 10-312(a). ⤴︎
  41. The ordinance provides the following two examples of acceptable safety locking devices: 1) a trigger lock that prevents a weapon from firing without a key; and 2) a “combination handle, which prevents the use of the weapon without the alignment of the combination tumblers.” ⤴︎
  42. Tessler v. City of New York, 952 N.Y.S.2d 703 (Sup.Ct. New York Co. 2012). ⤴︎
  43. 554 U.S. 570 (2008). ⤴︎
  44. Tessler, 952 N.Y.S. 2d 703. ⤴︎
  45. S.F. Police Code § 4512(a), (c)(2). ⤴︎
  46. Jackson v. City and County of San Francisco,746 F.3d 953 (9th Cir. 2014). ⤴︎
  47. 554 U.S. 570 (2008). ⤴︎
  48. Id. ⤴︎
  49. Sunnyvale Municipal Code § 9.44.040. ⤴︎
  50. Albany Municipal Code § 193-6. ⤴︎
  51. Id. ⤴︎