Lower court judges are struggling to make sense of the Supreme Court’s New York State Rifle & Pistol Association v. Bruen, more commonly known as the Bruen decision, while the number of mass shootings in the U.S. continues to climb.

The Bruen decision was passed by the Supreme Court 6-3 in June 2022, and it expanded rights for Americans to bear arms outside of their homes. Some people argue that the ruling supports the Second Amendment, which has become controversial in recent years due to arguments that it may or may not apply to the present day as much as when the U.S. Constitution was written. 

The Gun Violence Archive defines a mass shooting as a gun incident where four or more people are killed or injured, not including the shooter. America suffered 417 mass shootings in 2019 compared to 647 mass shootings in 2022. 

Additionally, as of Feb. 28 of this year, there have been 94 mass shootings in 2023 alone, according to The Gun Violence Archive. There have been more mass shootings than there have been days in 2023. 

Despite increasing numbers, it is unlikely that the Supreme Court will implement more gun restrictions, according to Ronald Steiner, a professor, director and pre-law advisor at Chapman University.

“It seems the Supreme Court is more likely to command that guns be much more widely available with far fewer restrictions,” Steiner said. 

Jordan Beal, a junior integrated educational studies major at Chapman, said that the Bruen decision may have impacted the rise in mass shootings after the court case was passed. 

“It’s definitely a contributing factor, because when we aren’t making positive changes, we are just sitting ducks,” Beal told The Panther. “We should be paying attention to why people are turning to gun violence. We should be investing in supporting those who are sick and need help, so that such horrid incidents are less likely to begin in the first place.”

The Bruen decision was a controversial case because of its support of the Second Amendment, which has been interpreted differently person to person.

“Part of me understands why they upheld the Second Amendment, but I also think that times have changed since it was written,” Beal said. “There were no automatic weapons then, and safety was probably a bigger issue for a multitude of reasons. However, with growth, change is necessary. It’s silly to think that while society has grown and evolved, everything in the Constitution still holds true.”

However, some interpret the Second Amendment as solely applying to America's military. 

“Recent developments in ‘big data’ analysis of language at the time the Bill of Rights was written has further confirmed that the phrase ‘bear arms’ was a reference to organized military service,” Steiner said. 

Gun rights supporters argue the Bruen decision removed what they see as unconstitutional restraints on Second Amendment rights.

News and media covering mass shootings has led to the anxiety of some American people. Fears of being a victim of a mass shooting are affected by aspects such as race/ethnicity, age, gender and political outlook, according to “Victimization: Examining the Fear of Mass Shootings,” a 2022 study conducted by Isa Alarcon, a sophomore political science major at Chapman.

Those who identified as Asian or Hispanic, and those who identified as women reported having more fear than others, according to the study. Younger generations and Democrats also tended to have a higher fear of becoming a victim than Republicans. 

While cases of mass shootings continue to climb in America, the question of how and why the country has been the place of so many acts of gun violence still stands, along with how to stop it. 

“A change definitely needs to be made. Gun violence is out of control, and at this point, it’s negligence,” Beal said. “It should not be this easy to buy automatic firearms, and there is really no need for the average person to have them.”