Tuesday, May 19, 2026

ICYMI: We Drove a Stake Through the Vampire Rule's Heart

Christian v. James (2d Cir. 2026). 

If "vampire rule" leaves you mystified, it is time to re-read one of the masterpieces of late Victorian literature: Bram Stoker's Dracula. In Stoker's novel, vampires could never enter a house uninvited. He used his hypnotic powers on Lucy Harkness (if my memory serves me correctly) to get her to invite him in. As Stoker's novel hints, Dracula's hypnotic powers were akin to spiking a young lady's drink.

Anyway, what is the connection? The fiercely anti-self defense states had to go shall issue on concealed carry licenses, but they were going to make licenses nearly useless by requiring licensees to get explicit invitation to carry in businesses open to the public, either by a sign in the window, or an expression permission from the owner. Imagine if you needed a sign "Black people are allowed" in a business window  

This decision struck down New York's rule on this while leaving intact its prohibition on licensees carrying in parks.

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