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On June 1, 2012, the U.S. Court of Appeals for the Second Circuit in United States v. Decastro analyzed a Second Amendment challenge to a firearm regulation using a substantial burden standard. In so doing, the Second Circuit ignored much of the Supreme Court’s guidance in its 2008 decision in District of Columbia v. Heller. This Comment argues that the Decastro substantial burden standard offers insufficient protection for Second Amendment rights, and is therefore unlikely to survive.