Massachusetts SJC Decision on Commonwealth vs. David E. Canjura: A Critical Examination of the Second Amendment and Knife Regulations

In the Massachusetts Supreme Judicial Court (SJC) case, Commonwealth vs. David E. Canjura (SJC-13432), the court tackled an essential constitutional issue involving the Second Amendment and the criminalization of carrying switchblade knives. The case revolved around the interpretation of the Second Amendment following the precedent set by the United States Supreme Court in New York State Rifle & Pistol Ass’n v. Bruen (2022) and the scope of "arms" under the Second Amendment.

The defendant, David E. Canjura, was arrested in 2020 after a domestic altercation and found with a switchblade knife, which under Massachusetts General Law c. 269, § 10(b), is considered a prohibited dangerous weapon. Canjura challenged the constitutionality of the statute, arguing that the prohibition against carrying a switchblade violated his Second Amendment right to keep and bear arms. After the trial court denied his motion to dismiss, the case was appealed, leading to the SJC’s significant ruling.

Factual Background of the Case

The incident that brought Canjura before the court occurred on July 3, 2020, when Boston police officers responded to an altercation between Canjura and his girlfriend. Witnesses alleged that Canjura had assaulted his girlfriend, leading to his arrest. During the arrest, police found an orange firearm-shaped knife with a spring-assisted blade, commonly known as a switchblade. Consequently, Canjura was charged under Massachusetts law for carrying a dangerous weapon and assault and battery on a family member.

Canjura’s defense did not dispute the nature of the knife as a switchblade but instead challenged the constitutionality of the law prohibiting its possession. His legal team argued that the ban on switchblades violated his Second Amendment right to bear arms for self-defense. The case eventually reached the Massachusetts SJC, which had to determine if switchblades, like firearms, are "arms" protected under the Second Amendment.

The Legal Framework: Second Amendment Analysis

The central issue in this case revolved around whether a switchblade qualifies as a protected “arm” under the Second Amendment, and whether Massachusetts’ prohibition on carrying such weapons could withstand constitutional scrutiny. To resolve this, the court applied the two-part test established by the U.S. Supreme Court in Bruen.

1. Step One: Does the Second Amendment Cover Switchblades?

The first step in the analysis is determining whether a switchblade falls within the meaning of "arms" as protected by the Second Amendment. The court referenced several landmark cases, including District of Columbia v. Heller (2008) and Caetano v. Massachusetts (2016), which expanded the definition of arms beyond firearms to include other bearable weapons, such as stun guns.

In Heller, the Supreme Court recognized that the Second Amendment extends to all bearable arms, not just firearms. The SJC in Canjura followed this reasoning, noting that knives, including switchblades, have historically been used for self-defense. The court concluded that a switchblade, as a type of folding pocketknife, fits within the historical definition of arms and is presumptively covered by the Second Amendment.

2. Step Two: Is the Prohibition Historically Justified?

Once the court determined that switchblades are arms under the Second Amendment, it moved to the second part of the test: whether the state’s regulation of switchblades is consistent with this nation’s historical tradition of regulating arms. Under Bruen, the government bears the burden of demonstrating that a modern-day regulation aligns with historical regulations of arms in place at the time of the Second or Fourteenth Amendments’ ratifications.

The Commonwealth argued that switchblades are "dangerous and unusual" weapons, designed primarily for stabbing and criminal purposes, and therefore outside Second Amendment protection. They pointed to historical regulations from the 19th century that restricted certain knives, such as bowie knives and dirks. However, the SJC found that these regulations did not apply directly to folding pocketknives like switchblades, which were commonly used for lawful purposes, including self-defense, at the time of the founding.

The court noted that knives, including folding pocketknives, were essential tools in colonial America, used not only for self-defense but also for everyday tasks like hunting and food preparation. The SJC ruled that the state’s regulation did not align with any historical tradition of banning similar types of knives and concluded that the Commonwealth failed to provide sufficient historical justification for the switchblade ban.

The "Common Use" Doctrine and Dangerous Weapons

A pivotal part of the Commonwealth’s argument rested on the claim that switchblades are not in "common use" today for lawful purposes and should therefore be excluded from Second Amendment protection as dangerous and unusual weapons. However, the SJC rejected this argument.

The court examined the legality of switchblades in other states, noting that only a handful of states and the District of Columbia outright ban switchblades. This widespread legality indicated that switchblades are in "common use" by law-abiding citizens across much of the United States. Moreover, the court held that switchblades are not uniquely dangerous compared to other knives, such as manual folding pocketknives, and do not possess any exceptional characteristics that would warrant exclusion from Second Amendment protections.

The Implications of the Ruling

The SJC’s decision in Canjura represents a significant extension of Second Amendment jurisprudence, broadening the scope of what constitutes protected arms beyond firearms to include knives, particularly switchblades. By applying the framework set forth in Bruen, the court struck down Massachusetts’ switchblade prohibition as unconstitutional, thereby reinforcing the notion that the Second Amendment protects a broader range of weapons than previously acknowledged.

This ruling could have far-reaching implications for knife laws and weapons regulations in Massachusetts and beyond. It underscores the trend toward a more expansive interpretation of the Second Amendment, limiting states’ ability to regulate arms that have traditionally been used for self-defense.

For defense attorneys and Second Amendment advocates, the Canjura decision provides a strong precedent for challenging state laws that restrict the possession of other types of weapons commonly used for lawful purposes. The case also signals that courts will increasingly rely on historical analysis when determining whether modern weapons regulations are constitutional.

On the other hand, state governments may need to reconsider their existing weapons regulations in light of this decision. While states still have the authority to impose reasonable regulations on arms, those regulations must now withstand rigorous constitutional scrutiny, with a clear historical basis supporting such restrictions.

Conclusion

The Massachusetts SJC’s ruling in Commonwealth vs. David E. Canjura is a landmark decision in the evolving interpretation of the Second Amendment. By affirming that switchblades are protected arms under the Second Amendment, the court has expanded the definition of bearable arms and placed greater limits on states' ability to regulate weapons. This case serves as a reminder that Second Amendment protections are not static and continue to evolve in response to modern-day legal challenges, with historical tradition playing a critical role in the analysis.