One thing you have to remember, unlike WA, ID and many other states, NY has no 2A equivilent in their state constitution, so all arguments have to be based on the bill of rights 2A.
NY does not want to see unbridled the right to bear arms in the 2A, so they will twist what does exist in any manner they can...this brief does not surprise me at all. Until the Supreme court comes out and flatly states that their is an unbridled right to carry anywhere you can legally be, there will be CA,NY, NJ, MD, MA, oh yes, and HI, Guam, the Marianna's etc.
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