Case Explained: GREGORY T. ANGELO v. DISTRICT OF COLUMBIA

Court: United States Court of Appeals for the District of Columbia Circuit

Filed: 2026-07-07

The D.C. Circuit reversed the district court’s dismissal of the plaintiffs’ Second and Fifth Amendment claims regarding the District of Columbia’s ban on carrying firearms on public transit, holding that the pistol owners have Article III standing to pursue declaratory and injunctive relief against all defendants and damages claims against the District. The court applied the “pocketbook injury” standard established in *Virginia v. American Booksellers Ass’n* and *Craig v. Boren*, determining that the plaintiffs suffered a concrete, particularized, and imminent injury-in-fact because the Metro Ban directly regulated their conduct and forced them to incur significant, ongoing economic costs by requiring them to use alternative, more expensive transportation modes rather than carrying their licensed firearms on the Metro system. The court distinguished this case from *Navegar* and *Clapper*, reasoning that unlike plaintiffs in those cases who faced speculative threats of prosecution or self-inflicted costs based on fear of surveillance, these plaintiffs are the direct targets of a law whose specific purpose is to compel costly behavioral changes, thereby satisfying the causation requirement for standing. The court affirmed the dismissal of damages claims against individual defendants in their official and personal capacities due to abandonment by the plaintiffs below and dismissed claims against Chief Anzallo in his official capacity on alternate grounds not appealed. The case is remanded to the district court for further proceedings consistent with this opinion.

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