State and federal governments have sought to protect victims of domestic violence by limiting abusers' access to firearms. For example, 18 U.S.C. 922(g)(8) disarms individuals who have been deemed a threat to their partners and are subject to protective orders. Approximately 48 states and territories have followed suit and adopted similar laws. Though lauded by victims' advocates as effective means for protecting the abused, these restrictions have also triggered a dispute about their constitutionality under New York State Rifle & Pistol Association (NYSRPA) v. Bruen, in which the U.S. Supreme Court held that restrictions on gun possession must comport with the nation's "history and tradition" of firearm regulation. The Supreme Court will resolve this Second Amendment dispute—and attempt to clarify the scope of the Bruen test—in United States v. Rahimi.

This case illustrates the inherent conflict between efforts to keep guns out of the hands of dangerous individuals while respecting the Second Amendment right to bear arms. Zackey Rahimi is an individual with a well-documented history of violence involving the use of handguns. This case arose from Rahimi's dispute with his girlfriend in 2019. During an argument, Rahimi grabbed his girlfriend by her wrist, shoved her to the ground, and then threw her in his car causing her to hit her head. Upon realizing bystanders had witnessed this physical altercation, Rahimi began shooting at them.