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Court Challenge

State Parks and Forests Carry Prohibition

Prohibited AreasState Pistol Permit

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: Unlike many other locations, a valid Connecticut State Pistol Permit does not 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 is not among the authorized exceptions, even for permit holders.

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 2024: The Second Circuit reversed and remanded, finding that Nastri had standing to bring the challenge based on a presumption of enforcement[5]
  • September 2025: On remand, U.S. District Judge Victor A. Bolden upheld the ban, finding that Connecticut parks and forests can be "quintessentially crowded places" or "frequented by children" and that there is a well-established history and tradition of prohibiting firearms in such locations[6]
  • Late 2025: The plaintiff filed an appeal to the Second Circuit Court of Appeals, and the opening brief has been submitted[6]
  • The case is now pending before the Second Circuit on appeal. Gun owners should be aware that the regulation remains in full effect during the pendency of the appeal.

    What to Watch

    The Second Circuit's decision in the Nastri appeal could establish important precedent on whether state administrative regulations banning carry in parks and forests satisfy the Bruen historical tradition test. Briefing is underway, and a decision is expected in the coming months. Regardless of the outcome, the firearms prohibition in state parks and forests remains enforceable unless and until a court orders otherwise.