In his concurring opinion, Justice Samuel Alito focused on the practical implications of the majority decision and addressed several concerns raised by the dissent. He argued that the right to self-defense is fundamental and that the historical context supports the interpretation that this right extends beyond the home. Alito stated, “[t]he exercise of other constitutional rights does not require individuals to demonstrate to government officers some special need. The Second Amendment right to carry arms in public for self-defense is no different.”

Alito dismissed the dissent's argument that the decision would lead to increased gun violence, arguing that there is no empirical evidence to support the claim that restricting the right to carry firearms reduces crime. Instead, he suggested that law-abiding citizens carrying firearms for self-defense could potentially deter criminal activity. Alito also addressed the historical analysis of gun regulations presented by the dissent. He pointed out that the historical evidence used to justify restrictive gun laws was either ambiguous or not analogous to the current laws in question and emphasized that the Second Amendment’s protection of the right to bear arms is deeply rooted in American history and tradition.

In his brief concurrence, Justice Brett Kavanaugh agreed with the Court’s ruling but wrote separately to highlight two issues. First, Kavanaugh explained that the Court’s decision did not prohibit states from imposing licensing requirements to carry a handgun for self-defense. He pointed out that the ruling only addressed the “unusual” discretionary licensing regimes used by six states. Kavanaugh wrote that “New York’s outlier may-issue regime is constitutionally problematic because it grants open-ended discretion to licensing officials and authorizes licenses only for those applicants who can show some special need apart from self-defense.” Second, Kavanaugh noted that when properly interpreted, the Second Amendment allows for a variety of gun regulations, but it is not a “regulatory straightjacket” or “regulatory blank check.”

In her brief concurrence, Justice Amy Coney Barrett noted that she fully joined the Court’s opinion but wrote separately to highlight to points unaddressed by the majority. First, Barrett pointed out that the Court does not determine specifically how post ratification practices bear on the original meaning of the Constitution. She highlights several different approaches but wrote that “[t]he limits on the permissible use of history may vary between these frameworks.”

Second, Barrett opined that the Court “avoids” the scholarly debate on whether courts should rely on the understanding of the Second Amendment at the time of its ratification in 1791, or the understanding of it when the Fourteenth Amendment was ratified in 1868. In this case, Barrett explained that the lack of support for New York’s law in either period allowed the court to ignore the question, but she noted the importance of clearly answering the question. Barrett ultimately concluded that “today’s decision should not be understood to endorse freewheeling reliance on historical practice from the mid-to-late 19th century to establish the original meaning of the Bill of Rights. On the contrary, the Court is careful to caution ‘against giving post enactment history more weight than it can rightly bear.’”