A federal judge has issued the first injunction against a “Glock ban” just a few months after another declined to do so.

On Wednesday, US District Judge Kari A. Dooley issued a preliminary injunction against Connecticut’s Public Act 26-41. That comes about two and a half months after US District Judge Monica Ramirez Almadani decided against granting a temporary restraining order against California’s Assembly Bill 1127. The two laws are nearly identical, as are the arguments in the two suits.

So, what were the key differences in the two rulings?

Well, the biggest distinction between them has to do with the underlying basis for each challenge. The Connecticut case, which combined two suits into one, featured Glock and other gun industry members challenging the ban. The California case featured the Department of Justice (DOJ) challenging the ban.

While both cases centered around arguments the ban violates the Second Amendment, the California case is predicated on DOJ’s claim that routine enforcement of the ban constitutes a “pattern and practice” of violating Californians’ Second Amendment rights. That’s the strategy the Department has been using in most of its Second Amendment cases, but the California case shows why it may be DOJ’s Achilles’ heel.

“While there may be merit to the United States’ claim that AB 1127 unlawfully restricts California constituents’ access to Glock and Glock-type pistols, the novel approach the United States employs to stake its claim is not obviously sound. To determine this novel issue, the Court will need to carefully interpret the statute and examine its plain language, legislative history, and historical usage, which it cannot achieve here due to the accelerated nature of a TRO,” Judge Ramirez Almadani wrote in US v. California. “Accordingly, the Court declines to grant the TRO given the uncertain viability of the United States’ claim pursuant to Section 12601.”

She labeled the DOJ’s interpretation of the federal law authorizing “pattern and practice” suits “unprecedented” and noted it has yet to succeed in other courts.

“The United States asserts a novel theory under Section 12601 that California is a governmental authority whose law enforcement officers are engaging in a pattern or practice of depriving individuals of their Second Amendment rights by enforcing AB 1127,” she wrote. “While there are several actions based on the novel use of Section 12601 pending throughout the nation, no court has determined whether the United States is authorized by the statute to facially challenge a state firearms law.”

Judge Dooley didn’t have to deal with that complication in the Connecticut case. Instead, he did a straightforward, if abbreviated, Bruen analysis to determine whether the plaintiffs were likely to succeed on the merits. And the first step was essentially uncontested.

“For purposes of the motion for preliminary injunction only, the Defendants accept that HB 5043 implicates the plain text of the Second Amendment,” Judge Dooley wrote in Glock v. Griffin. “Accordingly, the statute fails the inquiry at Step One of the Bruen analysis. This renders the statute presumptively unconstitutional.”

The next step involved more work, though. Connecticut offered up two analogues for its “Glock ban.” The first is proving laws from the early republic that mandated government inspections of gun barrels to show they were safe to use. Judge Dooley said those laws weren’t similar in purpose.

“Each of the proving laws discussed were designed to ensure safety before the firearm enters the stream of commerce,” he wrote. “They were not designed to, and indeed could not, forestall future misuse of the firearm (even if predictable) after it enters the stream of commerce. Here, there is no dispute that handguns with a cruciform trigger bar (in an unconverted state) are not only safe, but extremely popular for purposes of self-defense, and their possession and carry rights are protected by the Second Amendment.”

The other analogue was modern machine gun restrictions, which didn’t do anything to help convince Judge Dooley. Although, he did admit more information could come to light in a full hearing that could change his mind.

“Defendants’ argument is not without some force,” he wrote. “But the Court concludes that reliance on the proving laws, even when viewed through the lens of a legitimate regulation of machine guns, at this juncture, does not adequately rebut the presumption that the statute is unconstitutional under the Second Amendment. The Court agrees that this outcome may derive from the condensed time frame within which these issues have been presented and upon further development of the record, the outcome may well be different. But Defendants’ reliance on the proving laws would require, or at least suggest, that the firearms described in HB 5043, might be unsafe at the point of sale.”

Judge Ramirez Almadani did not reach any of those questions. But both judges did spend time on one similar aspect of their respective cases: whether the plaintiffs are irreparably harmed. And they came to opposite conclusions.

“AB 1127 does not prohibit the possession of semiautomatic machinegun-convertible pistols; it bans firearms dealers from selling the pistols,” Judge Ramirez Almadani, a Joe Biden appointee, wrote. “There are several exceptions to the law that allow for the continued acquisition of these pistols. For example, firearms dealers are permitted to sell remaining inventory of the convertible pistols received prior to January 1, 2026, and private individuals may acquire convertible pistols from private parties through a licensed firearms dealer.”

Judge Dooley knocked Connecticut for how it treats banned guns made before the ban. He argued that, rather than removing irreparable harm, it undermined the state’s position.

“[T]he Defendants offer no adequate explanation as to how the sale of a firearm manufactured on September 30, 2026 needs no safety regulation but the same firearm manufactured 24 hours later is sufficiently dangerous so as to be properly restricted and regulated by the state,” Judge Dooley wrote.

He also appeared to adopt the plaintiffs’ harm argument, which relied on loss of business and Second Amendment rights.

“Plaintiffs also argue that the existence of pre-October 1, 2026 manufactured firearms in their inventory (or in the case of NSSF their members’ inventory) does not address the concern identified by all Plaintiffs regarding the loss of a significant customer base, i.e., law enforcement personnel who are not exempted under the statute; the commensurate loss of good will; the disruption to current and anticipated contractual obligations; the stifling impact on their ability to advertise their products; the impracticality of carving Connecticut out of its advertising audience and perhaps most importantly, the impact upon Connecticut citizens whose Second Amendment rights are likely violated by HB 5043,” Judge Dooley wrote. “And as noted by Plaintiffs, although in Lamont, the Second Circuit left open the question of whether a Second Amendment violation is, de facto, irreparable harm, other courts to consider the issue have held that it is.”

Then, of course, there is a possible ideological difference between the judges. President Donald Trump appointed Judge Dooley. President Joe Biden appointed Judge Ramirez Almadani.

Other than the outcome of their rulings, there isn’t anything to really suggest either judge’s opinion was formed in part or in total by an ideological lean. But it’s no secret Democrats and Republicans pick judges with ideological outcomes in mind. And that has often had the intended effect, with judges often splitting along ideological lines in gun rulings.

Still, Dooley and Ramirez Almadani left themselves space to reconsider their rulings in a full hearing. So, there’s a possibility, however small, one or both could reconsider in the long run.