Well, the state got off to a great start. I see two problems just in their opening paragraph:
To obtain a license to carry a concealed handgun in public places without restriction, known as a “full-carry license,” an applicant must show “proper cause” for the license, N.Y. Penal Law § 400.00(2)(f) (Pet. App. 152), which New York courts have defined to mean a need for self-protection distinguishable from that of the general public. Klenosky v. N.Y City Police Dep’t, 75 A.D.2d 793, 793 (1st Dep’t 1980), aff’d on op. below, 53 N.Y.2d 685, 421 N.E.2d 503 (1981); accord Matter of Bando v. Sullivan, 290 A.D.2d 691, 693 (3d Dep’t 2002). In most parts of the State, and as relevant here, state judges are responsible for receiving and acting on applications for firearms licenses. N.Y. Penal Law § 265.00(10) (Pet. App. 148).
It was my understanding that ALL applicants, even for restricted licenses, have to show good cause.
Secondly, by acknowledging that the process is not the same for all residents of the state, the State is admitting that the process is either arbitrary and capricious, or that some citizens/residents of NY state are deprived of due process.
I haven't waded through the entire 25 pages yet. I'm sure it becomes more laughable from here.