Does a Hawaii law prohibiting licensed concealed-carry permit holders from carrying handguns on private property open to the public without express authorization violate the Constitution? Specifically, does this "flip" of the common-law default rule regarding implied consent infringe upon the right to bear arms? The Court must determine if such a restriction is consistent with the Second and Fourteenth Amendments.

• The law violates the Second and Fourteenth Amendments by severely restricting the ability of licensed citizens to carry handguns for self-defense during daily routines.
• It imposes an unconstitutional burden by requiring permit holders to obtain express permission before entering common locations like gas stations, restaurants, and stores.
• The law improperly flips the common-law default rule, which traditionally provides an implied license to enter property held open to the public unless the owner expressly withdraws consent.

• The right to bear arms does not encompass a right to enter private property without the owner's consent.
• Hawaii's unique customs and laws, reflecting the "spirit of Aloha," support a default rule requiring express authorization for armed entry.
• Historical analogues, including colonial anti-poaching statutes, demonstrate a tradition of prohibiting the carry of firearms on private land without permission.

• The Court held that Hawaii's law prohibiting licensed concealed-carry permit holders from carrying handguns on private property open to the public without express authorization violates the Second and Fourteenth Amendments.
• Applying the two-step framework from *New York State Rifle & Pistol Assn., Inc. v. Bruen*, the Court first found the law falls within the Second Amendment's plain text because it restricts "the people" from "bear[ing] Arms."
• Because the law falls within the plain text, it is presumptively unconstitutional unless the government can show it is consistent with the historical understanding of the right.
• The Court rejected Hawaii's reliance on local customs, noting in *McDonald v. Chicago* that the Second Amendment embodies a uniform national standard and cannot yield to local attitudes like the "spirit of Aloha."
• The Court found that colonial anti-poaching laws—specifically 1721 Pennsylvania, 1722 New Jersey, 1728 Maryland, 1763 New York, and 1771 New Jersey statutes—are not relevant analogues because they targeted unauthorized hunting on game lands rather than self-defense in retail establishments.
• An 1893 Oregon law was dismissed as being adopted too long after the Second and Fourteenth Amendments to illuminate the original meaning of the right.
• The Court rejected a 1865 Louisiana statute, noting it was part of the "Black Codes" intended to disarm Black citizens—a history that *McDonald v. Chicago* identifies as crucial to the Fourteenth Amendment's purpose.
• The Court concluded that Hawaii's new default rule imposes a significant burden on the fundamental right of self-defense recognized in *District of Columbia v. Heller*.