Public Carry and Public Health: Good Cause as a Good Solution

Document Type

Blog Post

Publication Date



Duke Law School




A heavily armed man, Dmitriy Andreychenko, walks into his local Walmart, and was eventually taken out in handcuffs. Another heavily armed man, Patrick Crusius, walked into his local Walmart and left under the same restraints. But only one, Crusius, had the intent to kill and left twenty-three dead and many others injured. Andreychenko was a “law-abiding citizen” with no intent to harm anyone and believed he was merely exercising his Second Amendment right to carry firearms in public. But in these seemingly identical scenarios, the public is powerless to determine an armed individual’s true intentions. The public cannot—and the law should not ask them to—make split second assessments of who is a threat and who is not. Instead, “good cause” requirements to carry firearms in public, which generally means providing a demonstrable need beyond self-defense interests, may provide a necessary balance between the rights of individuals who have reason to fear for their safety and the public’s fear of the growing gun violence crisis in this country.

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