Santagata v. Currier-Woods

Summary

The Appellate Division affirmed the denial of a petition challenging the rejection of an application for a full-carry pistol license. It held that the licensing officer had a rational basis for finding a lack of proper cause and good moral character, and rejected the petitioner’s Second and Fourteenth Amendment challenge by distinguishing the home-possession rights recognized in Heller and McDonald from the requested concealed-carry permit.

Holdings

1. The denial was supported by a rational basis and was not arbitrary and capricious.
2. The statutory licensing requirements, as applied to Santagata's application for a concealed full-carry permit, did not violate the Second or Fourteenth Amendments.

Questions Presented

1. Whether the licensing officer's denial of the full-carry pistol license had a rational basis or was arbitrary and capricious.
2. Whether Penal Law § 400.00's licensing eligibility requirements, as applied to Santagata, violated the Second and Fourteenth Amendments.

Disposition

affirmed