NY Gun Owners Guide

New York enacted the Sullivan Act in 1911, creating one of the nation’s earliest comprehensive systems for regulating concealable firearms. Named for State Senator Timothy “Big Tim” Sullivan, the law arose during rapid urban growth, political-machine government, labor unrest, street crime, and concern about concealed handguns. It criminalized unlicensed handgun possession and required government authorization to possess or carry one. Local police, judges, and licensing officials received substantial authority over who would receive a license.

The Act established the foundation for New York’s discretionary licensing system. For generations, applicants seeking an unrestricted concealed-carry license could be required to demonstrate “proper cause”—generally an exceptional need for armed protection beyond that of the general public. Critics argued that this discretion produced inconsistent county-level decisions, encouraged favoritism, and made access to a constitutional right dependent upon individual officials. Supporters maintained that local control allowed officials to evaluate applicants and community safety concerns.

The Sullivan Act remains important because New York’s handgun-licensing framework, Penal Law §400.00, developed from this system. In New York State Rifle & Pistol Association v. Bruen (2022), the Supreme Court held that New York’s proper-cause requirement violated the Second and Fourteenth Amendments. The Court did not invalidate handgun licensing. New York continues to require licenses for handgun possession and concealed carry, with applicants subject to eligibility standards, background investigations, character review, training, and administrative requirements. After Bruen, New York enacted the Concealed Carry Improvement Act, which remains under constitutional challenge.

The National Firearms Act of 1934 was Congress’s first major federal firearms-control statute. It followed highly publicized Prohibition-era violence involving machine guns, sawed-off long guns, and organized criminal groups. Rather than imposing a direct nationwide prohibition, Congress used its constitutional taxing authority to create a system of taxation and registration.

The NFA regulates machine guns, short-barreled rifles, short-barreled shotguns, silencers, destructive devices, and certain weapons classified as “any other weapon.” Making or transferring an NFA-regulated firearm generally requires an application to the Bureau of Alcohol, Tobacco, Firearms and Explosives, registration in the National Firearms Registration and Transfer Record, a background review, and payment of the applicable federal tax. The NFA remains part of Title 26 of the United States Code. Later federal law generally prohibited civilian possession or transfer of machine guns manufactured after May 19, 1986.

New York law is considerably more restrictive. The state generally prohibits civilian possession of machine guns, firearm silencers, short-barreled rifles, and short-barreled shotguns, except in narrowly defined circumstances or for specifically exempted persons. Therefore, obtaining federal approval or an NFA tax stamp does not make an otherwise prohibited weapon legal in New York. A person must comply with both federal and state law, and New York’s prohibition controls when it is stricter than the federal NFA requirements.

The Federal Firearms Act of 1938 represented one of the earliest nationwide efforts to regulate the commercial sale of firearms. Building upon the National Firearms Act of 1934—which focused primarily on machine guns and other specialized firearms—the 1938 Act shifted federal attention toward businesses that manufactured, imported, and sold firearms.

For the first time, individuals and companies engaged in the interstate firearms business were required to obtain a federal license. The law prohibited sales to certain individuals, including those convicted of violent crimes, and required licensed dealers to maintain basic transaction records. Although less detailed than today’s requirements, these provisions began a federal system for documenting firearm commerce. By focusing on commercial activity across state lines, the Act also established interstate commerce as the legal foundation for much of the modern federal firearms regulatory system.

The Act was an important milestone, but federal oversight continued to expand as concerns grew over crime, interstate trafficking, and mail-order firearm sales. These concerns ultimately led to the Gun Control Act of 1968, which repealed and replaced much of the 1938 law while significantly expanding federal licensing, recordkeeping, and firearm-transfer requirements.

Although the Federal Firearms Act no longer exists in its original form, its influence can still be seen throughout modern federal firearm law. It introduced the idea that firearm dealers could be federally licensed, that commercial firearm sales should be documented, and that certain individuals could be prohibited from purchasing firearms. Those concepts continue today through the modern Federal Firearms License (FFL) system, ATF oversight, background checks, and dealer recordkeeping requirements.

New York reorganized its criminal law during the 1960s, and Penal Law Article 265 became the principal location for offenses involving firearms and other dangerous weapons. Effective with the revised Penal Law in 1967, Article 265 brought numerous weapons provisions into a more organized statutory structure. It now contains definitions and crimes addressing unlawful possession, sale, transfer, manufacture, and transportation of regulated weapons. It also covers assault weapons, large-capacity ammunition feeding devices, firearm silencers, machine guns, disguised guns, unserialized firearms, unfinished frames and receivers, and possession in sensitive or restricted locations.

Article 265 is not a single, straightforward “gun law.” It is an interconnected network of definitions, criminal offenses, exemptions, and cross-references to other statutes, particularly New York’s licensing provisions in Penal Law §400.00. The legal classification of an object may determine whether possession is lawful, requires a license, or constitutes a misdemeanor or felony. Small differences in a firearm’s dimensions, operating system, magazine capacity, configuration, or serial-number status can change the legal result.

The circumstances of possession are equally important. Liability may depend on whether the firearm is considered “loaded” under New York’s unusually broad statutory definition, where it is possessed, how it is transported, and whether the possessor holds an appropriate license. Exemptions may apply to police officers, members of the military, licensed dealers, qualified competitors, or other specifically identified persons. Because definitions and exceptions are distributed throughout the law, no individual section should be interpreted in isolation.

Congress enacted the Gun Control Act of 1968 following the assassinations of President John F. Kennedy, Dr. Martin Luther King Jr., and Senator Robert F. Kennedy, amid national concern about mail-order firearm sales and interstate trafficking. The rifle used to assassinate President Kennedy had been purchased by mail. The Act replaced the Federal Firearms Act of 1938 and created the structure of the modern firearms regulatory system.

The GCA strengthened the Federal Firearms License system for manufacturers, importers, and dealers engaged in the firearms business. It restricted direct interstate transfers between residents of different states and generally required those transfers to proceed through federally licensed dealers. It also regulated firearm importation, required identifying markings and serial numbers on commercially manufactured or imported firearms, expanded dealer recordkeeping, and limited sales to minors.

The Act established broad categories of people prohibited from receiving or possessing firearms, including most convicted felons, fugitives from justice, certain unlawful drug users, and persons found mentally incompetent or committed to mental institutions. Congress later expanded these categories and added further protections through amendments.

Many familiar dealer procedures developed from the GCA and subsequent federal legislation. These include completion of ATF Form 4473, verification of a purchaser’s identity and residence, retention of transaction records, and compliance with federal transfer restrictions. The Brady Act later added the national background-check system. The GCA remains primarily codified in Title 18 and continues to form the foundation of federal firearms commerce regulation.

The Bureau of Alcohol, Tobacco and Firearms became a separate bureau within the Department of the Treasury in 1972. Its creation separated the Alcohol, Tobacco and Firearms Division from the Internal Revenue Service and consolidated federal responsibility for enforcing laws involving firearms, explosives, and alcohol and tobacco taxation.

Following passage of the Homeland Security Act, most of ATF’s firearms and explosives responsibilities transferred to the Department of Justice in 2003. The agency was renamed the Bureau of Alcohol, Tobacco, Firearms and Explosives, while retaining the abbreviation ATF. Alcohol and tobacco tax and trade functions generally remained within the Treasury Department under the Alcohol and Tobacco Tax and Trade Bureau.

ATF administers and enforces major portions of the Gun Control Act and National Firearms Act. It reviews applications for Federal Firearms Licenses, conducts compliance inspections of licensed businesses, regulates firearm transfers and manufacturing activities, and issues rulings and guidance. ATF also investigates unlawful firearm trafficking, prohibited-person possession, thefts from federally licensed dealers, arson, bombings, and criminal misuse of explosives.

Through the National Tracing Center, ATF assists law-enforcement agencies by tracing firearms recovered during criminal investigations from the manufacturer or importer through the distribution chain to the first retail purchaser. These traces are investigative tools and are not the same as a national firearm registry. The FBI, rather than ATF, operates the National Instant Criminal Background Check System, although both agencies perform distinct roles in federal firearms regulation, licensing, enforcement, and public safety.

The Firearm Owners’ Protection Act of 1986 revised the Gun Control Act of 1968. The Act clarified what it means to be “engaged in the business” of dealing in firearms, distinguished commercial dealing from occasional personal sales or collection activity, limited most ATF compliance inspections without a warrant to once annually, and strengthened protections against the creation of a federal firearm registry. It also relaxed several earlier restrictions on ammunition sales and interstate activities by licensees.

One of FOPA’s best-known provisions is the interstate safe-passage protection contained in 18 U.S.C. §926A. It generally protects a person transporting a firearm between two places where the person may lawfully possess and carry it. During transportation, the firearm must be unloaded, and neither the firearm nor ammunition may be readily accessible from the passenger compartment. In a vehicle without a separate trunk, they generally must be secured in a locked container other than the glove compartment or console.

FOPA is frequently misunderstood. It is not a national carry permit and does not override every state or local restriction. Extended stops, overnight stays, unnecessary deviations, or activities beyond continuous transportation may complicate or defeat a safe-passage claim. Travelers must also be legally entitled to possess the firearm at both the origin and destination.

The legislation also included the Hughes Amendment, which generally barred civilian possession or transfer of machine guns not lawfully possessed before May 19, 1986, subject to limited governmental and law-enforcement exceptions.

The Brady Handgun Violence Prevention Act of 1993 transformed the way federally licensed dealers transfer firearms. It was named for James Brady, President Ronald Reagan’s press secretary, who was permanently disabled after being shot during the 1981 attempted assassination of the President.

Initially, it established an interim system for handgun purchases from federally licensed dealers. Dealers generally had to provide information to the purchaser’s local chief law-enforcement officer and wait five business days before completing the transfer, unless the officer approved it sooner. This temporary system was intended to allow time to determine whether the prospective purchaser was legally prohibited from receiving a firearm.

In 1998, the National Instant Criminal Background Check System replaced the interim waiting-period system. NICS is operated by the FBI and searches federal and state records for disqualifying information. Before transferring a firearm, a dealer contacts NICS directly or submits the transaction through a state point of contact. The response may be “proceed,” “denied,” or “delayed.” A delay means additional research is needed; it is not automatically a denial.

New York became a NICS point-of-contact state for firearm transactions in 2023. Dealers submit firearm background checks through the New York State Police, which communicates with NICS and state databases. New York also requires state background checks for ammunition purchases, a requirement that goes beyond the federal Brady system. Dealers must follow the applicable federal and state procedures and cannot disregard a required check, delay, or denial.

The federal Assault Weapons Ban was enacted in 1994 as part of the Violent Crime Control and Law Enforcement Act. It prohibited the manufacture, transfer, and possession of certain semiautomatic firearms defined by military-style features, as well as models identified by name. The law also prohibited the manufacture and transfer of newly produced large-capacity ammunition feeding devices capable of holding more than ten rounds. Firearms and magazines lawfully possessed before the effective date were grandfathered, allowing their continued possession and transfer under federal law.

The federal ban included a ten-year sunset provision and expired on September 13, 2004. The expiration did not invalidate or preempt separate state restrictions.

New York enacted its own assault-weapons law in 2000, largely continuing the federal definitions and restrictions within the state. Unlike the federal law, New York’s version did not contain the same 2004 sunset. In 2013, the New York Secure Ammunition and Firearms Enforcement Act, commonly called the SAFE Act, expanded those restrictions. It generally changed the firearm-feature test from two prohibited features to one, broadened the categories of regulated firearms, required registration of many previously possessed assault weapons, and strengthened magazine restrictions.

New York generally prohibits possession of magazines capable of holding more than ten rounds, subject to limited exceptions. Although the SAFE Act attempted to limit most loading to seven rounds, that provision was held unconstitutional by a federal court. Consequently, federal expiration did not restore unrestricted possession in New York.

IIn District of Columbia v. Heller (2008), the United States Supreme Court held that the Second Amendment protects an individual right to keep and bear arms for lawful purposes, independent of service in an organized militia.

The Court invalidated the District’s prohibition on handgun possession in the home. It also struck down a requirement that lawful firearms kept in the home be unloaded and disassembled or secured with a trigger lock, because the rule prevented their immediate use for self-defense. The Court emphasized that self-defense, particularly within the home, lies at the core of the Second Amendment right. It also directed the District to permit Heller to register his handgun and issue him a license if he was otherwise qualified.

Heller was a landmark decision, but it did not hold that every weapon, every person, every location, or every manner of carrying firearms is constitutionally protected. The Court stated that the right is “not unlimited.” It described several longstanding regulations as presumptively lawful, including prohibitions on firearm possession by felons and the mentally ill, restrictions in sensitive places such as schools and government buildings, and conditions on the commercial sale of firearms.

The opinion also distinguished weapons commonly possessed for lawful purposes from “dangerous and unusual” weapons. Because the District of Columbia is a federal jurisdiction, Heller did not decide whether the Second Amendment applied to the states. That question was answered two years later in McDonald v. Chicago.

In McDonald v. City of Chicago (2010), the United States Supreme Court held that the individual Second Amendment right recognized two years earlier in District of Columbia v. Heller applies to state and local governments through the Fourteenth Amendment. Before McDonald, Heller directly restricted only the federal government and the District of Columbia, leaving unresolved whether states and municipalities were constitutionally bound by the same protection.

The case arose from Chicago ordinances that effectively prohibited ordinary residents from possessing handguns in their homes. In another 5–4 decision, the Court concluded that the right to keep and bear arms for lawful self-defense is fundamental to the American system of ordered liberty.

A plurality of the Court applied the Second Amendment to the states through the Fourteenth Amendment’s Due Process Clause. Justice Clarence Thomas agreed with the result but relied on the Privileges or Immunities Clause. Although the Justices differed on the constitutional path, five agreed that state and local governments must respect the individual right recognized in Heller.

McDonald did not invalidate every state or municipal firearm regulation, nor did it establish a complete test for evaluating all gun laws. Instead, it made those laws subject to constitutional review. The decision opened the door to challenges involving licensing, carrying firearms in public, prohibited weapons, and other state restrictions. Its impact on New York was especially important because it allowed residents to challenge New York firearm laws directly under the Second Amendment.

New York enacted the Secure Ammunition and Firearms Enforcement Act, commonly called the SAFE Act, in January 2013, approximately one month after the Sandy Hook Elementary School shooting.

The SAFE Act broadened New York’s definition of an “assault weapon.” For many semiautomatic rifles, pistols, and shotguns, it changed the prior two-feature test to a one-feature test. The law generally prohibited new acquisition of covered assault weapons and required many lawfully possessed before the Act to be registered with the New York State Police.

The Act strengthened New York’s ten-round magazine restriction and originally attempted to prohibit loading more than seven rounds in most circumstances. A federal court later invalidated the seven-round loading limitation, but the general ten-round capacity restriction remained. The law also required background checks for many private firearm transfers, subject to limited exceptions; expanded mental-health reporting procedures; increased penalties for certain firearm offenses; and imposed additional safe-storage responsibilities in specified circumstances.

The SAFE Act generated continuing litigation, regulatory interpretation, enforcement questions, and administrative changes. Some provisions were invalidated, modified, delayed, or affected by later legislation, but its principal assault-weapon and magazine framework remains central to New York law.

A firearm lawful under federal law, or lawfully available in another state, is not necessarily lawful in New York. Its features, operating system, configuration, magazine capacity, registration history, and acquisition date may determine its legal status. Each firearm must therefore be evaluated under current New York definitions and applicable exemptions.

Jaime Caetano carried a stun gun after receiving threats from an abusive former partner. Massachusetts prosecuted her under a state ban. The Massachusetts high court concluded that stun guns were outside the Second Amendment because they were not in common use when the Second Amendment was adopted and were considered unusual.

The U.S. Supreme Court unanimously vacated that judgment. Its short per curiam opinion rejected the reasoning that a weapon loses constitutional protection merely because it did not exist in the eighteenth century. Justice Alito’s concurrence emphasized Caetano’s use of a non-lethal defensive weapon to protect herself from a violent abuser.

Caetano did not create a nationwide rule eliminating all regulation of stun guns, and it did not decide the law governing every less-lethal product. It did establish an important principle: the Second Amendment extends to bearable arms beyond those known to the Founding generation.

In Caetano v. Massachusetts (2016), the United States Supreme Court rejected the idea that stun guns fall completely outside Second Amendment protection merely because they did not exist when the Amendment was adopted. The case involved a Massachusetts prohibition, not New York law, but it helped establish that electronic defensive devices may qualify as protected “arms.”

Relying partly on Caetano, a federal court in Avitabile v. Beach (2019) held that New York’s complete civilian prohibition on possessing stun guns and electronic dart guns violated the Second Amendment. The court concluded that the state could not maintain a total ban on devices commonly possessed for lawful self-defense. As a result, New York could no longer enforce its blanket prohibition as written against ordinary, law-abiding civilians.

The decision did not mean that stun guns, TASER-type devices, or other electronic defensive tools became completely unrestricted. A person prohibited from possessing weapons may still face criminal liability. Possession may also be restricted in schools, government buildings, secure facilities, or other locations governed by state, federal, or local rules. Additional restrictions may apply based on the person’s age, conduct, or circumstances.

Most importantly, lawful possession does not authorize unlawful use. Displaying, threatening with, or discharging an electronic defensive device without legal justification may constitute assault, menacing, reckless endangerment, or another offense. Use in self-defense must satisfy the same general principles of necessity, proportionality, and reasonableness that apply to other defensive force under New York law.

In New York State Rifle & Pistol Association v. Bruen (2022), the United States Supreme Court held that New York’s “proper cause” requirement for an unrestricted public-carry license violated the Second and Fourteenth Amendments. The Court concluded that ordinary, law-abiding citizens do not need to prove an exceptional danger before exercising the right to carry a handgun publicly for self-defense.

Bruen also changed the method courts must use to evaluate Second Amendment challenges. It rejected the two-step approach under which courts first considered whether conduct was protected and then balanced the right against the government’s public-safety interests. Instead, when the Second Amendment’s plain text covers an individual’s conduct, that conduct is presumptively protected. The government must then demonstrate that its regulation is consistent with the Nation’s historical tradition of firearm regulation.

The decision did not eliminate handgun licensing. The Court distinguished New York’s discretionary “may-issue” system from “shall-issue” systems. Requirements such as background checks, fingerprinting, training, and verification of eligibility were not categorically invalidated, provided they are administered through objective standards and are not used to prevent citizens from exercising the right.

Bruen also recognized that firearms may be prohibited in sensitive places, such as schools and government buildings. However, the Court cautioned against declaring areas sensitive simply because people gather there. After Bruen, constitutional disputes shifted toward where firearms may be carried and whether licensing requirements, fees, delays, training mandates, and location restrictions improperly burden the right..

New York passed the Concealed Carry Improvement Act (CCIA) in 2022 after the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen. The CCIA removed the old “proper cause” requirement, but added new rules for obtaining a concealed-carry license and carrying a handgun in public. It expanded the application process, added training requirements, created vehicle-storage rules, and banned firearms in many “sensitive” and “restricted” locations.

Most new concealed-carry applicants must complete sixteen hours of classroom instruction and two hours of live-fire training. Applicants must also pass a background investigation, provide character references, disclose certain household information, complete an in-person interview, and meet all other state and local requirements.

The CCIA lists many places where firearms generally cannot be carried, including schools, government buildings, polling places, and certain public gatherings. It also attempted to make private property off-limits unless the owner gave permission. Federal court decisions, including Wolford v. Lopez, have seriously weakened that permission-first rule.

When a handgun is left unattended in a vehicle, it generally must be unloaded, hidden from view, and secured in a locked, fireproof, and impact-resistant container.

Several parts of the CCIA have been challenged in court. Court orders and later decisions have changed which rules may be enforced. Students should check current law instead of relying on old handouts or social-media posts.

Current New York guidance: gunsafety.ny.gov

Beginning September 4, 2022, New York requires a person to hold a state license before purchasing or taking possession of a semiautomatic rifle. The minimum age for acquiring one is generally twenty-one. Applications are handled through the appropriate county or local licensing authority under Penal Law §400.00. A person who already holds a New York pistol license may apply to have semiautomatic-rifle authority added, while a person without a pistol license may apply for the rifle license separately.

The requirement focuses on acquisition, not continued possession. A person who lawfully acquired a semiautomatic rifle before September 4, 2022, generally may continue possessing it without obtaining the new license. However, selling, exchanging, giving, or otherwise transferring a semiautomatic rifle to an unlicensed person may create criminal liability for both parties.

The license is permission to purchase or take possession; it is not approval of every semiautomatic rifle. A firearm classified as an assault weapon under Penal Law Article 265 remains prohibited unless a specific exemption or lawful prior registration applies. Features such as a detachable magazine, pistol grip, folding or telescoping stock, threaded barrel, muzzle device, or other listed characteristics may affect its classification.

The purchaser must also complete the required dealer transfer and background-check process. Private transfers generally must pass through a licensed dealer unless a statutory exception applies. Buyers should therefore verify both their licensing status and the rifle’s configuration before completing any purchase, gift, exchange, or other transfer.

Rahimi involved the federal prohibition on firearm possession by a person subject to a qualifying domestic-violence restraining order. The Supreme Court held that the law was constitutional as applied to a person found by a court to pose a credible threat to another’s physical safety.

The Court clarified Bruen’s historical method. A modern law does not need an identical historical twin. It may be upheld when it is relevantly similar in why and how it burdens the right and fits a historical tradition of disarming persons who threaten physical harm.

Rahimi is especially important because it shows that Bruen is not a rule that automatically invalidates modern firearm restrictions. Courts must examine text, history, purpose, operation, and the specific application before them.

In Bondi v. VanDerStok (2025), the Supreme Court considered whether the Gun Control Act and ATF’s 2022 regulations may treat certain weapon-parts kits and unfinished frames or receivers as “firearms.”

The challengers argued that ATF had exceeded its authority because a collection of parts is not yet an operable weapon and an unfinished frame or receiver is not yet complete. The Court rejected their facial challenge. It held that the Gun Control Act can cover some kits that are designed to become functional firearms or may readily be converted into them. The Court also concluded that some partially complete frames or receivers may be regulated when they have reached a stage where they can be considered a frame or receiver.

The ruling did not declare that every collection of firearm parts, raw material, or incomplete component is automatically a firearm. How readily the item can be completed, the work and tools required, the product’s design, and the way it is marketed may affect the determination. The decision allows ATF to apply federal serialization, licensing, recordkeeping, and background-check requirements to covered products.

VanDerStok was primarily a case about the meaning of the Gun Control Act and the validity of an agency regulation. The Court did not decide whether the Second Amendment protects a right to manufacture an unserialized firearm. Its lesson is that an item’s unfinished condition or “kit” label does not, by itself, place it beyond federal firearms law.

In United States v. Hemani (2026), the Supreme Court considered a federal law that bans an “unlawful user” of a controlled substance from possessing a firearm. Hemani admitted using marijuana about every other day and kept a gun in his home. The government did not claim that he was addicted, dangerous, or armed while under the influence.

The Court ruled that the law was unconstitutional as applied to Hemani. Under Bruen, the government had to show that this prosecution matched America’s historical tradition of firearm regulation. The government compared the law to older laws involving habitual drunkards, but the Court found that comparison too weak. Those historical laws applied to different people, for different reasons, and in different ways.

The ruling was narrow. It did not erase the entire federal law or create a general right to mix drugs and firearms. The Court did not decide cases involving drug addiction, present intoxication, dangerous behavior, or proof that a person’s drug use creates a danger to themselves or others.

New Yorkers must remain careful. Marijuana may be legal under New York law in some circumstances, but federal controlled-substance law, firearm-purchase forms, and federal dealer requirements still apply. New York licensing officers may also consider an applicant’s drug use, judgment, and legal eligibility.

The basic lesson is limited: regular marijuana use alone was not enough to disarm Hemani permanently without proof connecting his use to addiction, intoxication, or danger.

In Wolford v. Lopez (2026), the Supreme Court reviewed a Hawaii law about carrying handguns on private property that is open to the public. Under Hawaii’s law, a person with a concealed-carry license could not carry there unless the property owner gave permission.

The Supreme Court ruled that this automatic ban violated the Second and Fourteenth Amendments. The Court explained that the law placed a serious burden on licensed citizens. It forced them to obtain permission from every business owner or look for a sign that allowed firearms before entering while armed.

The decision does not take away a private owner’s control over the property. An owner may still prohibit firearms, ask an armed person to leave, or post a “no firearms” sign. The problem was Hawaii’s rule that treated almost all private property open to the public as off-limits unless the owner first said “yes.”

New York adopted a similar rule in Penal Law §265.01-d. New York’s law generally treated private property as a restricted location unless the owner or authorized person gave clear permission to carry. Federal courts had already limited enforcement of that rule before Wolford.

Because Wolford came from Hawaii, it did not directly erase every part of New York’s law. Because New York adopted the same basic permission-first system, Wolford makes clear that the state cannot automatically turn ordinary businesses open to the public into no-carry zones for licensed citizens.