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.