Gun Owners’ Action League (GOAL) says Massachusetts just crossed a constitutional line.
In an update on the federal challenge Hanlon v. Campbell, GOAL reports that Attorney General Andrea Campbell’s office filed its official answer and then claimed the Commonwealth is shielded from the suit by sovereign immunity under the Eleventh Amendment.
GOAL’s account frames this as more than a routine defense tactic – it’s a signal that the state believes federal courts can’t touch its new “Assault Style Firearms” law at all.
According to GOAL, the complaint – filed with the National Rifle Association and several licensed gun owners – targets sweeping penalties on commonly owned semi-automatic firearms and related restrictions.
They argue the law violates the Second Amendment, the Fourteenth Amendment, and the Supreme Court’s Bruen test.
That’s the backdrop. The fireworks start in the state’s “affirmative defenses.”
“We’re Immune” – And Everything Else Is Denied
GOAL quotes the Commonwealth’s first affirmative defense plainly: sovereign and Eleventh Amendment immunity “bar Plaintiffs from seeking or obtaining relief.”
In other words, Massachusetts argues you can’t even get a federal court to declare or enforce federal constitutional limits against state officials here.
GOAL calls that posture an overreach – and points straight to Ex parte Young (1908), the Supreme Court decision that allows suits against state officials to stop ongoing violations of federal law. In their view, this is Civics 101: you can’t wall off constitutional review by invoking state immunity when the claim is that state officers are violating federal rights.
The rest of the answer, GOAL says, is blanket denial. The Commonwealth denies the law is unconstitutional, denies the weapons are in common use, and denies that the plaintiffs have standing or injury.
GOAL argues that this is a familiar pattern in anti-gun jurisdictions post-Bruen – slow-walk, deny, and dare the courts to intervene.
GOAL’s Executive Director Jim Wallace doesn’t mince words.
He likens the state’s stance to past episodes where local governments defied landmark civil-rights rulings, saying the Attorney General’s filing “emphasizes the arrogance of our state government.”
A YouTuber’s Read: “Declaration of War on 2A”
On his Guns & Gadgets 2nd Amendment News channel, Jared Yanis goes further. He calls the filing “the most pompous and arrogant” response he’s read in years and says Massachusetts “declared war” on its own citizens’ rights.
Yanis summarizes the state’s moves this way: deny every constitutional claim, insist the bans are lawful, and even contend that AR-15s and similar rifles are not “in common use” for lawful purposes.
He highlights how the answer challenges standing, injury, and ripeness – classic kill-the-case arguments designed to keep judges from reaching the merits.
He also flags a key point for gun shops. In his telling, the state’s position would leave licensed dealers like Pioneer Valley Arms with no constitutional protection for engaging in lawful firearms commerce. To him, that’s not regulation – it’s erasure.
Even if you don’t share Yanis’ tone, his summary of the defenses tracks the strategy GOAL describes: wall off federal review, deny the factual premise of “common use,” and try to knock out the case on justiciability.
The Eleventh Amendment Gambit, Explained
Let’s pause on the immunity claim because it’s the hinge.
GOAL emphasizes Ex parte Young for a reason. The doctrine is a staple of federal courts: when a state officer is allegedly violating federal law, you can sue that officer in federal court for prospective relief – injunctions and declarations – despite the state’s sovereign immunity.
That’s precisely how countless constitutional challenges proceed against governors, attorneys general, and agency heads.
So why invoke Eleventh Amendment immunity anyway? Because if a court buys even part of it, the state narrows who can be sued and what can be ordered.
At a minimum, it forces plaintiffs to be precise: name the right official, show an ongoing violation, and tie that official to enforcement. If the judge finds those links missing, the case can stall or be refiled, time that favors the government.
GOAL’s bottom line is simple: this isn’t a close call. They see the filing as a dare to the federal judiciary and, ultimately, the Supreme Court.
The New Fight Over “Common Use”
From Heller to Caetano to Bruen, courts have keyed on whether a weapon is “in common use” for lawful purposes. GOAL says Massachusetts denies that status to AR-15-style rifles despite their widespread civilian ownership.
Yanis latches onto that, calling it “a constitutional slap in the face” to Supreme Court precedent.
His point is political and practical: millions of Americans own modern semiautomatic rifles; claiming they’re not commonly used strains credulity and invites a bruising evidentiary fight the state is likely to lose.
Expect this to be one of the earliest skirmishes. Plaintiffs will marshal market data, sales numbers, training and competition use, and defensive-gun-use examples.
The state will try to reframe “common use” around frequency of defensive deployment or argue the firearms are “dangerous and unusual,” outside Second Amendment protection. That’s where history-and-tradition analysis under Bruen collides with modern reality.
What GOAL Says This Means for Massachusetts
GOAL argues the Commonwealth’s posture confirms what gun owners feared when the “modernizing” bill was drafted: state leaders intend to defy Bruen the way some jurisdictions once resisted Brown v. Board of Education.
They cite Massachusetts’ track record in Caetano – where the U.S. Supreme Court rebuked the state’s high court over stun guns – as a cautionary tale for Beacon Hill.
Their warning is less about rhetoric than trajectory. If the Commonwealth stakes out immunity, denies common use, and insists there’s no injury, they see it as a coordinated strategy by all three branches of state government to outlast federal scrutiny.
It’s a serious charge. It will live or die on how the case is handled in court over the next few months.
Hardball Now, Supreme Court Later
Two things can be true at once.
First, Massachusetts is playing hardball. The Eleventh Amendment move is crafted to force procedural fights before any judge reaches the Bruen merits. The denials on common use and standing are designed to shrink discovery and keep the record thin.
From a pure litigation strategy standpoint, that’s not shocking. It’s exactly how deep-blue states have defended gun laws since Bruen – make plaintiffs win three times, not once.
Second, GOAL and Jared Yanis are right about the stakes. If AR-15-style rifles aren’t “in common use,” nothing is.
If Ex parte Young doesn’t permit a suit against the AG and enforcement officials, little does. If licensed dealers lack any constitutional shield for lawful commerce, the right to acquire arms becomes theoretical.
That’s why this case matters nationally. Whether you agree with GOAL or not, these are the pressure points that decide the shape of Second Amendment doctrine for the next decade.
What Happens Next
If the court follows the usual path, expect briefing on immunity, standing, and ripeness first. If plaintiffs clear those hurdles – and GOAL’s Ex parte Young argument is strong – the judge will turn to preliminary-injunction standards under Bruen’s text-and-history test.
On the merits, the “common use” record could be decisive. Plaintiffs will try to lock in undisputed facts about ownership and lawful purposes; the state will try to carve narrower categories and emphasize risk.
Parallel cases around the country have already produced mixed results at the lower-court level, but Bruen’s framework is the north star – and appellate courts have begun to realign around it.
GOAL predicts this one could reach the Supreme Court because of how bluntly the Commonwealth framed its defenses. Yanis thinks the same, arguing Massachusetts “dared” the justices to act.
That isn’t guaranteed, but it’s plausible. The Court tends to intervene when lower courts or governments read its Second Amendment rulings too narrowly – or ignore them.
GOAL says Massachusetts just tried to place its gun law beyond federal reach. Jared Yanis says that’s a declaration of war on the Second Amendment.
Even stripped of rhetoric, the state’s answer signals an aggressive, high-stakes defense built on immunity, denial, and delay.
If the court lets those defenses stand, the right will be decided on paper.
If the court pushes past them, the right will be decided on evidence.
Either way, Hanlon v. Campbell is now a bellwether. And for gun owners in Massachusetts, it’s not academic. It’s about whether the Constitution follows you home – or stops at the state line.
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A former park ranger and wildlife conservationist, Lisa’s passion for survival started with her deep connection to nature. Raised on a small farm in northern Wisconsin, she learned how to grow her own food, raise livestock, and live off the land. Lisa is our dedicated Second Amendment news writer and also focuses on homesteading, natural remedies, and survival strategies. Lisa aims to help others live more sustainably and prepare for the unexpected.