1. This lawsuit challenges Defendants’ actions mandating and enforcing the closure of all outdoor firearm training ranges in the State. This action effectively bans typical, law-abiding
citizens in the State of New Jersey from exercising their constitutional right to practice with firearms to gain and maintain proficiency in firearms use.
2. Prohibiting training with firearms is akin to prohibiting the exercise of Second Amendment rights altogether. “The right to possess firearms for protection implies a corresponding right to acquire and maintain proficiency in their use; the core right wouldn’t mean much without the training and practice that make it effective.”
3. Despite the centrality of range-training to the exercise of Second Amendment rights, Governor Murphy has, since March 21, 2020, banned that activity throughout the State of New Jersey with the stroke of a pen, effectively preventing New Jersey’s citizens from obtaining or maintaining their proficiency in firearms use. Governor Murphy’s ban is flatly contrary to the Second Amendment.
4. The existence of the COVID-19 pandemic does not justify Governor Murphy’s actions. Plaintiffs recognize that the pandemic presents significant and urgent problems for state officials seeking to ensure the safety and well-being of citizens of New Jersey. But the State’s untenable regulatory choices refute any assertion that COVID-19 requires New Jersey to shut down all outdoor gun ranges…………….