Wehr-Darroca v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedSeptember 22, 2025
DocketCivil Action No. 2024-3504
StatusPublished

This text of Wehr-Darroca v. District of Columbia (Wehr-Darroca v. District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wehr-Darroca v. District of Columbia, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

WILLIAM D. WEHR-DARROCA, et al., : : Plaintiffs, : Civil Action No.: 24-cv-3504 (RC) : v. : Re Document No.: 11 : DISTRICT OF COLUMBIA, et al., : : Defendants. :

MEMORANDUM OPINION

GRANTING DEFENDANTS’ MOTION TO DISMISS

I. INTRODUCTION

This is a pre-enforcement constitutional challenge to a D.C. gun regulation. Defendants,

the District of Columbia and two D.C. officials, have moved to dismiss the complaint for lack of

subject-matter jurisdiction. The Plaintiffs—two individual gun owners and a nonprofit advocacy

group—concede that under binding D.C. Circuit precedent they do not have standing. What they

want is for the D.C. Circuit sitting en banc or the Supreme Court to overturn that precedent. So

unlike the usual case, this litigation presents no factual or legal disputes for the Court to resolve.

This Court’s role is to grant the motion to dismiss.

II. BACKGROUND

In 2009, the District of Columbia banned firearm magazines capable of holding more

than ten rounds of ammunition, which it labeled “large-capacity magazines.” D.C. Code

§ 7‑2506.01(b) (2009) (“the Ban”); see Firearms Control Amendment Act of 2008, D.C. Law

17‑372, 56 D.C. Reg. 1365 (May 2, 2009). The Ban provides that “[n]o person in the District

shall knowingly possess, sell, or transfer any ammunition feeding device that is, in fact, a large

capacity ammunition feeding device, regardless of whether the device is attached to a firearm.” D.C. Code § 7-2506.01(b). A “large capacity ammunition feeding device” is defined as “a

magazine, belt, drum, feed strip, or similar device that has a capacity of, or that can be readily

restored or converted to accept, more than 10 rounds of ammunition.” Id. § 7-2506.01(c).

Possession of a large-capacity magazine is a felony. Id. § 7-2507.06(a)(4).

In 2011, the D.C. Circuit upheld the Ban as constitutional. See Heller v. District of

Columbia (“Heller II”), 670 F.3d 1244, 1264 (D.C. Cir. 2011). But after the Supreme Court in

New York State Rifle & Pistol Association v. Bruen articulated a purely historical test for Second

Amendment claims, 597 U.S. 1, 18–26 (2022), a group of plaintiffs brought a renewed a

challenge to the Ban. See Hanson v. District of Columbia (“Hanson I”), 671 F. Supp. 3d 1

(D.D.C. Apr. 20, 2023). This Court denied their motion for a preliminary injunction, concluding

that they were unlikely to succeed on the merits. Id. at 8–25. The D.C. Circuit affirmed and

additionally held that the plaintiffs had not satisfied the other two preliminary injunction factors:

irreparable harm and the balance of the equities. See generally Hanson v. District of Columbia

(“Hanson II”), 120 F.4th 223 (D.C. Cir. 2024).

Shortly after the Circuit issued its decision in Hanson II, two gun owners who live and

reside in D.C., William Wehr-Darroca and Gary Stemple, and the Firearms Policy Coalition

(“FPC”), a Nevada-based interest group, brought this suit again challenging the Ban’s

constitutionality. Compl. ¶¶ 16–19; 24–77. They name as Defendants the District; Pamela A.

Smith, the acting Chief of Police of the Metropolitan Police Department; and Brian L. Schwalb,

the Attorney General for the District of Columbia (collectively, “Defendants”). Id. ¶¶ 20–22.

Their one-count complaint seeks injunctive and declaratory relief. Id. at 22.

Both Wehr-Darroca and Stemple are licensed to carry concealed weapons within D.C.

Id. ¶¶ 62–63, 66. They also both own registered handguns that come, by default, with magazines

2 capable of holding more than 10 rounds of ammunition. Id. ¶¶ 63, 67. Because those magazines

are banned in the District, Wehr-Darroca and Stemple had to purchase replacement magazines

that are compatible with D.C. law. Id. But for the Ban, both individual Plaintiffs would keep

and bear magazines capable of holding more than 10 rounds. Id. ¶¶ 64–65, 68–69. Neither

individual Plaintiff has been “specifically” threatened with enforcement of the Ban “beyond the

threat to the general population.” Id. ¶ 70. FPC claims at a high level of generality that the Ban

injures its members, including Wehr-Darroca and Stemple. Id. ¶¶ 16–17, 19.

Defendants filed a motion to dismiss arguing that the three Plaintiffs lack standing under

binding D.C. Circuit precedent. Defs.’ Mot. Dismiss Pls.’ Compl., ECF No. 11; Mem. P. & A.

Supp. Defs.’ Mot. Dismiss Pls.’ Compl. (“Mot. Dismiss”), ECF No. 11. Plaintiffs filed an

opposition conceding that they do not have standing. Pls.’ Mem. P. & A. Opp’n Defs.’ Mot.

Dismiss (“Pls.’ Opp’n”), ECF No. 13. Defendants then filed a reply. Reply Br. Further Supp.

Defs.’ Mot. Dismiss Pls.’ Compl. (“Defs.’ Reply”), ECF No. 14. The motion to dismiss is thus

ripe for review.

III. LEGAL STANDARD

Standing is an “irreducible constitutional minimum” that requires the party invoking the

court’s jurisdiction to establish three elements. Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61

(1992). First, the plaintiffs must show that they suffered an “injury in fact,” or a harm that is

“concrete” and “actual or imminent, not ‘conjectural’ or ‘hypothetical.’” Whitmore v. Arkansas,

495 U.S. 149, 155 (1990) (quoting Los Angeles v. Lyons, 461 U.S. 95, 101–02 (1983)). Second,

they must demonstrate “a fairly traceable connection between [his proffered] injury and the

complained-of conduct of the defendant.” Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83,

103 (1998). And third, it must be “‘likely,’ as opposed to merely ‘speculative,’ that the injury

3 will be ‘redressed by a favorable decision.’” Lujan, 504 U.S. at 561 (quoting Simon v. Eastern

Ky. Welfare Rights Org., 426 U.S. 26, 38, 43 (1976)). Injury in fact “requires that the party

seeking review be himself among the injured.” Sierra Club v. Morton, 405 U.S. 727, 735

(1972). An organization may have standing on behalf of its members if “(1) at least one of [its]

members has standing to sue in his or her own right, (2) the interests the association seeks to

protect are germane to its purpose, and (3) neither the claim asserted nor the relief requested

requires the participation of an individual member in the lawsuit.” Elec. Priv. Info. Ctr. v. U.S.

Dep’t of Com., 928 F.3d 95, 101 (D.C. Cir. 2019) (internal quotation omitted).

At the pleading stage, “general factual allegations of injury resulting from the defendant’s

conduct may suffice.” Lujan, 504 U.S. at 561. If a plaintiff lacks standing, the complaint must

be dismissed for lack of subject-matter jurisdiction. See Fed. R. Civ. P.

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Related

Sierra Club v. Morton
405 U.S. 727 (Supreme Court, 1972)
City of Los Angeles v. Lyons
461 U.S. 95 (Supreme Court, 1983)
Whitmore Ex Rel. Simmons v. Arkansas
495 U.S. 149 (Supreme Court, 1990)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
Seegars, Sandra v. Ashcroft, John
396 F.3d 1248 (D.C. Circuit, 2005)
Parker v. District of Columbia
478 F.3d 370 (D.C. Circuit, 2007)
Ord v. District of Columbia
587 F.3d 1136 (D.C. Circuit, 2009)
United States v. Medina-Martinez
396 F.3d 1 (First Circuit, 2005)
Heller v. District of Columbia
670 F.3d 1244 (D.C. Circuit, 2011)
Lashawn A. v. Marion S. Barry, Jr.
87 F.3d 1389 (D.C. Circuit, 1996)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)

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