## Facts

- Police responded to a report that BB pellets were being fired into a neighbor’s window from a nearby house.
- Officers encountered the defendant’s 18-year-old son, who appeared to have developmental disabilities.
- The son admitted firing a BB rifle kept in his bedroom closet.
- When asked about other guns, the son produced two firearms owned by the defendant.
- One firearm had a trigger lock; the other was unsecured (not in a locked container and not disabled by a tamper-resistant lock or similar safety device).
- The defendant was charged under Mass. Gen. Laws ch. 140, § 131L(a), which requires firearms not under the owner’s (or authorized user’s) control to be stored in a locked container or locked/disabled to prevent operation by unauthorized persons.

## Issues

1. Whether the Second Amendment, as interpreted in District of Columbia v. Heller, limits Massachusetts’s authority to enforce its firearm safe-storage statute.
2. If the Second Amendment applies to the states, whether § 131L(a) impermissibly burdens the right to keep an operable firearm in the home for self-defense.

## Decision

- The Supreme Judicial Court reversed the trial court’s order dismissing the safe-storage charge and vacated the dismissal.
- Relying on then-controlling Supreme Court precedent, the court held the Second Amendment did not apply to the states and therefore did not invalidate § 131L(a).
- Alternatively, assuming the Second Amendment applied, the court held § 131L(a) consistent with the self-defense right recognized in Heller because it regulates storage when the firearm is not under immediate control rather than requiring inoperability at all times.
- The case was remanded for further proceedings on the storage charge.

## Legal Principles

- Under then-controlling federal precedent, the Second Amendment constrained the federal government but did not restrict state firearm regulation.
- A safe-storage requirement that permits an operable firearm when carried by or under the immediate control of an owner (or authorized user) does not necessarily violate the constitutional protection for possessing firearms for self-defense in the home.
- Regulations aimed at preventing unauthorized access and accidental or unlawful use may be upheld where they do not eliminate the ability to keep a functional firearm available for immediate defensive use.
- A statutory “control” limitation may be read to allow ready access for self-defense while requiring locking or disabling when the firearm is unattended.

## Conclusion

The court reinstated the firearm safe-storage charge, holding that the Second Amendment did not then limit Massachusetts’s statute and that, even if applicable, the statute permissibly required secured storage only when the firearm was not under the owner’s immediate control.


Commonwealth v. Runyan, 922 N.E.2d 794 (Mass. 2010)