Defensive Gun Use Proves Armed Citizens Aren’t ‘Vampires’

by Amy Swearer and Isabel Guerrero, Daily Signal, October 16, 2025

Earlier this month, the Supreme Court agreed to hear a challenge to a Hawaii gun law that renders concealed carry permits in that state practically useless. While the nation’s highest court appears poised to strike down the law, it nonetheless indicates gun control advocates’ deep misunderstanding of the importance of the right to armed self-defense.

In 2022, the Supreme Court struck down restrictions on concealed carry permits that states like Hawaii used to eliminate the right of public carry for most ordinary, law-abiding citizens. In response, Hawaii and several other states passed a series of spiteful measures—including the so-called “Vampire Rule” now before the court—intentionally designed to make as many public places as possible off-limits to gun owners.

The name “Vampire Rule” derives from old folklore that a vampire can’t enter a home unless first invited inside by the owner.

Historically, the default rule for public carry presumed that lawful gun owners could carry firearms on private property unless the owner expressly prohibited it. Hawaii’s law, however, turns this historical default on its head, essentially treating concealed carry permit holders like vampires.

It presumptively bans concealed carry permit holders from carrying firearms on private property—including private property that’s open to the public, such as stores, restaurants, and other businesses—unless the owner affirmatively grants them express permission.

While this might not seem like a big deal at first glance, the lower courts that upheld the law freely acknowledged that, regardless of the default rule, most private property owners will decline to post any signs that give or revoke specialized permission. As a practical matter, then, the rule all but ensures that the vast majority of public spaces remain “Second Amendment-free” zones. Indeed, this was the law’s entire goal.

In reality, Hawaii residents have far more to gain from exercising their Second Amendment rights in public than their politicians are willing to admit. It’s not just that concealed carry permit holders are among the most law-abiding members of society and rarely commit crimes of any nature. It’s that, on the whole, lawful gun owners are incredibly effective at stopping the violence so often committed by unlawful gun owners.

Almost every major study—including the most recent report on the subject by the Centers for Disease Control and Prevention—has found that Americans use their firearms in self-defense between 500,000 and 3 million times annually. In 2021, a professor at the Georgetown McDonough School of Business conducted the most comprehensive study ever on the issue, concluding that roughly 1.6 million defensive gun uses occur in the U.S. every year.

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