State Parks and Forests Carry Prohibition

Connecticut Administrative Code Section 23-4-1 establishes a broad prohibition against carrying firearms in state parks and forests. The regulation states that "hunting or carrying of firearms, archery equipment or other weapons, including but not limited to air rifles and slingshots, is not permitted in any state park or forest except as authorized by the Department of Energy and Environmental Protection."^[1]

Scope of the Prohibition

The ban is broad in several respects:

• Applies to all weapons: The regulation covers firearms, archery equipment, air rifles, slingshots, and any other weapons
• Covers all state parks and forests: The prohibition extends to every state park and state forest in Connecticut, not just specific locations
• No permit exception: A valid Connecticut State Pistol Permit does not by itself authorize carry in state parks and forests
• Enforced by Environmental Conservation Police: Officers from the Department of Energy and Environmental Protection (DEEP) enforce this regulation^[2]

Limited Exceptions

The regulation allows exceptions only "as authorized by" DEEP. In practice, these authorized activities include:^[3]

• Hunting during designated seasons in areas specifically opened for hunting by DEEP
• Use of firearms at designated firing ranges within state parks or forests
• Activities specifically permitted by DEEP through special authorization

Carrying a firearm for personal self-defense in a state park or forest requires authorization from DEEP even if the person has a permit to carry.

Legal Challenge: Nastri v. Dykes

The constitutionality of this regulation is being challenged in Nastri v. Dykes. Filed in January 2023, the case argues that Administrative Code 23-4-1 violates the Second Amendment because it prevents permit holders from carrying a handgun for self-defense in state parks and forests, and because the regulation has no historical analogue that would justify it under the framework established in New York State Rifle & Pistol Association v. Bruen (2022).^[4]

The case has had a complex procedural history:

• July 2023: The U.S. District Court for the District of Connecticut initially dismissed the case on standing grounds
• March 29, 2024: The Second Circuit vacated the judgment and remanded in light of intervening Second Circuit law on standing in pre-enforcement Second Amendment challenges^[5]
• September 30, 2025: On remand, U.S. District Judge Victor A. Bolden granted summary judgment to the state on the facial and as-applied challenges and denied a permanent injunction. He held that Sleeping Giant State Park and the Farmington Canal Trail are "quintessentially crowded" places within the Nation's well-established tradition of regulating firearms^[6]
• October 2, 2025: Nastri appealed to the Second Circuit (No. 25-2413)^[6]

The appeal, No. 25-2413, is pending before the Second Circuit. The district court denied injunctive relief, and the regulation remains in effect while the appeal is pending.

What to Watch

The appellant's reply brief was filed on May 6, 2026. Oral argument was set for November 3, 2026, and on September 1, 2026 the court granted the state's motion to adjourn it. Regardless of the outcome, the firearms prohibition in state parks and forests remains enforceable unless and until a court orders otherwise.