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By Lee Williams

The U.S. Supreme Court’s opinion in New York State Rifle & Pistol Association, Inc., v Bruen, which lifted restrictions on carrying defensive firearms and changed forever how lower courts must adjudicate Second Amendment challenges, has created a massive amount of pushback. 

Bruen was a big win for gun owners, because the Second Amendment is no longer to be treated as a second-class right. In response, Democratic lawmakers have been introducing Bruen response laws that they know are unconstitutional. Many have similar language, which indicates it’s an organized campaign, most likely by the White House. 

Lawmakers aren’t the only ones throwing tantrums and pushing back against one of the most significant Second Amendment opinions ever. Now, a group of doctors have released “research” that specifically targets the Supreme Court’s Bruen decision, and the activist docs have thrown in two more high-court opinions – COVID mandates and abortion – just for good measure.  

The doctors’ report, which they called an “original investigation” was published Thursday by the Journal of the American Medical Association, or JAMA. We’ll let readers decide for themselves what they think of the docs’ COVID and abortion findings, but their Bruen research speaks for itself.

Their results are sophomoric and more than a little silly. However, what the report makes crystal clear is the need to zealously monitor any attempt to use taxpayer dollars to fund anti-gun “research,” or we’ll end up neck-deep in biased agitprop such as this. 

The research 

In their report, which is titled: “Projected Health Outcomes Associated With 3 US Supreme Court Decisions in 2022 on COVID-19 Workplace Protections, Handgun-Carry Restrictions, and Abortion Rights,” the researchers tried to ascertain the “probable health consequences” of the three decisions. 

Interestingly, they only considered anti-gun jurisdictions named in the Bruen case: California, Hawaii, Maryland, Massachusetts, New York, New Jersey, and the District of Columbia, but acknowledged that the decision, “could have much broader impacts, potentially culminating in the lower courts invalidating numerous gun regulations throughout the nation.” That much is certainly true. 

The researchers then “estimated” – think wild-ass guess – how the restoration of gun rights would impact 2020 firearm death statistics in the seven jurisdictions, using three estimates: low (0% effect on gun deaths), middle (4.5% increase), or high estimate (a 9% increase). 

Inherent bias 

The researchers attacked the Bruen decision right from the start, quoting one anti-gun scholar, John Donahue, who noted . . .

Bruen has created an unworkable and largely nonsensical standard for evaluating gun regulations based on history when the history has very little to say about wise policy today. Hopefully, the standard will not be used to invalidate important tools to address gun violence, such as state bans on assault weapons and high-capacity magazines, red flag laws, safe storage laws, waiting periods, and other sensible measures designed to reduce the large social costs of gun violence in America. But the standard is so vague and malleable that this Supreme Court will be able to sustain – or strike down – any of these measures and many more.

Dubious sources

For their report, the researchers used a variety of notable anti-gun and left-leaning sources, some of which include the following: The Washington Post, Politico, The New York Times, JAMA, The Los Angeles Times, the Duke Center for Firearm Law, The Boston Globe, and The Trace, the propaganda arm of former New York City mayor Michael Bloomberg’s anti-gun empire. 

The researchers also admitted they used Twitter, Instagram and Facebook posts as sources.


Sticking their finger firmly into the wind, the Bruen decision, the researchers found, “will result in the rain 152 additional firearm-related deaths annually,” adding, “We also projected 377 additional nonfatal firearm-related injuries (with lower and upper bounds of 0 and 754). These injuries include an estimated 29 serious head or neck injuries, 51 serious chest injuries, 37 serious abdominal or pelvic injuries, and 77 serious extremity injuries in our primary scenario.” 


Anything the Journal of the American Medical Association publishes about guns is immediately suspect, because the AMA has taken the position that “gun violence” is a public health crisis. The AMA created a gun violence prevention task force, which has more than 30 policy recommendations, most of which would infringe upon our Second Amendment rights. 

Just as in another recent anti-gun JAMA article, this latest report illustrates the time-tested GIGO principle – garbage in, garbage out. It’s hard to take the authors’ work seriously when their sources include The Trace, a bevy of hoplophobic liberal newspapers, and social media posts. 

As to the report itself, the idea that of a handful of activist doctors could somehow estimate the number of casualties attributed to a Supreme Court ruling in six states and the District of Columbia is downright laughable. Like so many JAMA articles, this one is nothing more anti-gun agitprop thinly disguised as medical research. 


The Second Amendment Foundation’s Investigative Journalism Project wouldn’t be possible without you. Click here to make a tax deductible donation to support pro-gun stories like this.

This story is part of the Second Amendment Foundation’s Investigative Journalism Project and is published here with their permission.


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  1. Inherent bias, biased sources, and the false correlation = causation basis all over it — does not a valid study make.

    • I can only speak for NY but a year later we are still trending upwards in violent crime at the same rate we have been throughout the pandemic and that is directly tied to bail/sentencing reform re not locking up as many criminals with violent tendencies until it is unavailable. If Bruen has had any effect it has been more pistol permits in NYC as even with all the new bullshit laws it’s still an improvement down there.

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    • Yes, they may be correct that 153 more people may be shot.
      But if the gunshot victims are rapists, muggers, and other criminals shot by law abiding concealed carriers, then society is better off with these people shot dead.

  2. So, what did the study on “no bail catch and release” of violent felons find… Oh wait, did they DO a study on that? Of course not…

      • Statistically speaking, numbers like they came up with in their study are arrived at by pulling them directly from their asses 96.875 percent of the time.
        JAMA… Just Another Medical Accident. Who here gives a rats ass what they have to say anyway?

    • Oh we did the studies, they may never be anything more than an astrix somewhere buried deep in the data but bail reform absolutely was a major contributor over the last 3 years. Fentanyl especially mixed in with everything making drugs more cost efficient to sell didn’t help much either. Recidivism reports is where one probably could find some of the info in NY.

  3. If you to wish to see the crap going on in the medical community check with your State Board of Medical Examiners for cases of complaints, arrests, etc. all against assumed to be goody two shoes doctors, etc. In other words, jama has no podium.

  4. Maybe they should figure out how to reduce malpractice deaths which are 250-400K a year based on estimates.

    • Andrew,

      Nah, that would require them to actually ‘stay in their lane’, focus on things they (supposedly) have some knowledge about . . . and police their own profession. Man, that’s just crazy talk!!

  5. Gee Wiz, 152? not 147? how about 155? 170? More nonsense, when I see studies like that my B.S. detectors go to Defcon 3. They have no idea, nobody does. Well, God does and he’s not speaking to anyone right now. Humans are creatures of free will and conflicting emotions and therefor react in random and unpredictable ways. Given the same data, 5 different groups people may come up with 5 entirely different predictions. Given enough time, monkeys with typewriters could come up with the novel “War and Peace”.

  6. “Will Result in at Least 152 Additional Gun Deaths In 6 Anti-Gun Jurisdictions”

    Well, the more likely is is that a law abiding person is armed with a firearm the more likely the criminals that attack them will be shot. But I’m sure that’s not all they want to include, but its always a nuance they like to exclude.

    Seriously though, correlation does not equal causation and that’s most of what this ‘study’ was. The fact that Bruen did away with an unconstitutional ‘government’ activity that was specifically created and used to deny a constitutional right is something that should not be done? What if that unconstitutional action was applied to first amendment rights, amendment, would it be OK then for SCOTUS to say something about it? Our founders and even the constitution its self demanded that such unconstitutional activity not be permitted to infringe on the 10 amendments in the Bill of Rights, its called tyranny.

    So as much as they want to claim that SCOTUS did something ‘wrong’, SCOTUS did not do anything wrong with Bruen and in fact did exactly what it was created for and envisioned to do and that is to keep government in check, keep tyranny at bay, ensure laws are constitutional, and uphold the Constitution.

    Our government, federal and state, have over-stepped their constitutional authority for wayyyy too long. The recent EPA case at SCOTUS for example, stopped the clearly unconstitutional activity of agencies usurping the law making power of Congress by their creating defacto-law by ‘rule/regulation’. There are hundreds of examples just in the last two years where agencies of government both federal and blue states have created unconstitutional defacto-law by ‘rule/reglation’ and in some blue states flat out state legislature law created that is clearly unconstitutional in an effort to gain some more control over constitutional rights and the people and its tyranny plain and simple.

    This was never supposed to happen, the founders warned against it, and yet the left-wing complain about a stop being put to it by the very branch of government that’s suppose to do that in the form of SCOTUS then want to claim we are a democracy when they don’t get their way of tyranny flavor. We are eaten up with tyranny from all directions, for all of the 10 inherent constitutional rights not just the second amendment, and they don’t expect someone to stand up and say “NO, this is not going to happen.” ? Then they want to blame what seems is the only entity (SCOTUS) putting a stop to it while at the same time not dealing with criminals and mental illness causing 99.9% of what they complain about and their answer is ‘take away the rights of the law abiding’ to solve a problem they are creating.

  7. Is this essentially the same bunch of doctors that told us we should all have the MRNA crap jabbed into our bodies? How about doing a “study” about the hundreds of thousands that have been permanently injured by that, or better yet, the countless ones who have died.
    From personal experience, professors and others with big degrees tend to have little common sense. Probably the same with these.

  8. Medical huh? I guess anything to distract from the number of preventable medical mistakes which is likely vastly under-reported but the number is estimated to be close to 500,000 a year.

  9. Had a physical two weeks ago. My Doc (whom I duck hunt with) is unhappy with the increasing pressure placed on Doctors by the AMA and other “Professional” organizations to push the anti-gun propaganda.

  10. “From personal experience, professors and others with big degrees tend to have little common sense”

    True dat my friend

  11. JAMA long ago got their 30 pieces of silver. No one should expect actual scientific information to be presented therein.

  12. “Social Media, The Trace Show Bruen Will Result in at Least 152 Additional Gun Deaths In 6 Anti-Gun Jurisdictions”

    Its a stupid nonsense-conclusion to begin with because they don’t know that there would not be “152 Additional Gun Deaths In 6 Anti-Gun Jurisdictions” if Bruen didn’t exist. Its junk-science fortune-telling mumbo jumbo of the left-wing anti-gun once again.

    • I will admit I did not read the full report so may have missed it.BUT.. all I can see from this piece is the bald claim of some numbers related to some other factors….. and a list of a whole roaboatload of skanky “sources”. Nowhere did I see one speck of actual work. Bare fact in a causal relationship with the undesired outcome or result.

      When I see some statements with solid sources underlying (instead of simply LYING) a cause-effect factor together with the basis for stating the signficance of the connection, maybe I’ll take a nanosecond or three and go over their data. But thus far I’ve not SEEN anything that might even remotely resemble “data”. When George in Manhattan no longer must “prove” the uproveable (that he WILL NOT misuse his right to arms) and can thus simply go and buy a handgun to go with that cool holster he’s been trying to fill for five years he will then join the ranks of law abiding gun possessors in his state/city….. who already have a well documented “crime rate” invilving guns about one-sixth the statistical rate of harming innocents with their guns. So what? Further this nonsense report utterly fails to take into consideration the now-vastly increase in the use of defensive gun, thus REDUCING the rates of violence in those same areas. Including the rates of recidivism. And possibly even reduce their numbers, now enough more will be armed and thus able to shoot back.

      Back when I was in CawLidge if I had ever slipped such loaded bin of rubbish to any of my profs I’d have gotten my fantasy paper returned to me with a simple four letter word attached: REDO

  13. So, will that magical 152 additional deaths be criminals, crime victims, or suicides? Perhaps just accidents?
    How about this. let those who wish to keep and bear arms do so, and allow those who wish to be unarmed victims do so. So many of these anti gun studies are so badly done and so biased it’s become comical.

    • ine of the two tribes mentioned above will increase, the other will decrease. I’m glad I’m in the group that INcreases.

  14. It just doesn’t make any sense right from the jump, why would more law abiding people carrying a firearm cause (that many) more deaths? The statistics say otherwise. Evidently they didn’t plug that little number into their equation, you know, the one about CCW folks being so much less likely to commit crimes. Seems like that little part would be an important piece to a “study” such as this one.

    • no name,

      I can cite you similar statistics for the American Bar Association (which has a similar Leftist’/fascist bias). There is the old saying that “Any organization not explicitly conservative (and, I would posit, many that began as “explicitly conservative”) over time becomes overtly liberal”. I can say for an absolute fact that, over my years in practice, the ABA became WILDLY Leftist/fascist (when I joined, it was a little center-left; today it is a freakin’ joke).

      My working theory is that ALL “trade associations” (which is all the hell the AMA are, or have ever been) trend Leftist (government is a good tool to help them achieve their ACTUAL goal of protecting their members from competition) being Leftish (if not full, outright Communist), and trend more authoritarian/Left over time. I’d love to see a REAL study on it, but that’s my long-term observation.

  15. Membership was 271,660 in 2022. … (There are over a million professionally-active physicians and med students in the US.)

    Between 1998 and 2020, the [AMA] has spent an average of $18 million annually on lobbying efforts. In the first quarter of 2021, they reported $6.36 million in lobbying expenses. — Wikipedia

    • Walter,

      Oh, I have MANY words for this “study”. Some of them might even pass our vaunted TTAG “moderation” (depending on the day, mood, subject, and what the moderator had for breakfast).

      A few obvious ones?


      or, my favorite, (not one word, but work with me, here): Lies.

      As Samuel Langhorne Clemens said, “Figures don’t lie; but liars figure”. ‘Nuff said.

  16. Did they analyze the population that is responsible for the most violence before and after Bruen? You know, the criminals?

    Will the criminal increase activity because of Bruen? What if the criminal finds those the prey ipon areno longer prey and can equalize the battle ground? Will that lower the propensity to prey on others?

    Come on JAMA, show is the work.

  17. Translation: The U.S. Supreme Court ruled against us, so we are going to throw a temper tantrum, and then do what we want anyway. So I suppose when the time comes that the courts flip the other way against the Second Amendment, the rulings should not mean anything in that case, either?

        • Dear Borg: thank you for taking the time to “inform” us of your intentions against us. Please be on notice that we will NOT be assimilated easily. You may well get some of us, but you will NEVER get all of us. We who remain will avenge those who do not. You have been warned.

  18. Those 152 additional deaths will all be violent criminals killed by armed citizens defending themselves.

    Sounds good to me.

  19. I’m not wasting my time reading the bs study.
    My question is how many lives will be saved in the states that put even minimal restrictions on abortion?

    • Idea…..
      hows about we make all gang members, thugs, drug dealers etc. have mandatory health insurance that they pay for.So taxpayers and those of us that have to pay for insurance quit getting screwed

      • I dont think you can make a gang members do anything. Besides theyd just shoot some old lady to pay the ins premium

  20. Yes there certainly will be an additional 152 shot dead criminals because of the Bruen decision. Plus and additional 377 wounded criminal survivors. Unfortunately.

  21. Have at it JAMA! Keep ruining your once trusted and good name to keep being the good little ideologue foot soldiers you think you are! No one with a brain is buying the garbage spoon fed to them anymore….. actually strike that…. Far too many people are still, however a lot more are paying attention.

    Facts and data are no longer on the side of the anti 2a leftists.

    Also…… the decision is written law now. Let them destroy their good name just as the cdc and the medical establishment did during covid.

  22. You gotta pump those numbers up, those are rookie numbers in this racket.

    I think lawful armed residents can kill a lot more felons, in the act, in California alone. Adding the deceased scum felons of New York, Maryland and D.C. we could really get those numbers up!

    • Even if we accept their “numbers”, they are, indeed, “rookie numbers” – barely a statistical blip in the overall numbers. And that is without considering all the OBVIOUS analysis/methodological issues I raised (below), or the whole “lack of any evidence of causation”, even if their numbers ARE true. This is just a stupid, virtue-signaling piece of Leftist/fascist idiocy (and probably a fair amount of “publish or perish”). The authors are ridiculous @$$clowns.

  23. With this kind of solemn announcement from the “authorities”, it might be wise to check their confidence level. Ask them this: “If you’re wrong, can we break your legs?”
    This would give them skin in the game and might cause them to recheck their math.
    If they won’t agree, I feel free to ignore their nonsense.

  24. Even were the numbers accurate, they pale astronomically in comparison to the worlds where total citizen gun bans have been implemented……Germany pre-WWII, Russia early 1900s, Cambodia, China, et el. America’s “gun” carnage….rather Defective Citizen Carnage….isn’t even a rounding error to those scenarios. I’ll take my chances as an armed citizen against armed Evil rather than as an unarmed subject against an armed State.

  25. I have to admit, I am daunted by how to even APPROACH commenting on this embarrassing POS. It is rife with bias (both ‘confirmation bias’ and outright “we’re gonna try to blow smoke you your @$$” bias, sloppy methodology (including, particularly, sample size/collection), questionable assumptions, unstated assumptions, and an overall lack of professional/scholarly tone/tenor/rigorousness/. Apparently, Leftist/fascist/authoritarians are incapable of honesty or self-reflection (I was hoping MajorLiar and dacian the demented were just particularly heinous examples).

    Just a FEW of the OBVIOUS flaws in this completely flawed POS:

    1. Just read the first paragraph (“Questions”). I suppose there is a weak argument that this was inserted to give lip service to a professional/scholar/researcher obligation to try to eliminate, or at least DISCLOSE, obvious bias. If that was the authors’ intent, it should have been explicit – but I think we all know it wasn’t That same bias PERVADES the “study”, the written report on the “study”, the methodologies used, and the “sources” cited.

    2. Why just those states (in re: the Bruen/2A issue)???? One obvious objection to the conclusion, for even a CASUAL observer, is that THOSE STATES are exactly the ones who are busily ignoring Bruen and the 2A. Virtually all of them have passed/proposed legislation, since Bruen, that is obviously antithetical to both the 2A and the holding in Bruen. Not likely that ANY of them are going to adopt a Bruen-compliant gun regulation agenda unless FORCED to by a SCOTUS decision (and probably not even then). Nor, in terms of sample selection, are those even the six states with the lowest per capita “gun crime”. Nor were they chosen at random; their selection was quite intentional.

    3. Even their statement of their “Objective” is absurd. Their description of the three SCOTUS decisions they are allegedly studying describes their result as “. . . invalidated workplace COVID-19 vaccine or mask-and-test requirements, voided state handgun-carry restrictions, and revoked the constitutional right to abortion.” NONE of those three is either remotely true, as an objective description, nor legally correct, in terms of their ACTUAL legal holding and impact.

    I could go on for a post that would rival MajorLiar and dacian the demented in length (although mine would at least be coherent) – taking apart their assumptions (to the extent that they even IMPLICITLY stated them, which they mostly didn’t), the “sources” they cited (and in some cases, purported to rely on), They did not address, AT ALL, obvious predicate questions (as just one example, in their “discussion” of their methodology, and their conclusions, of the results of the OSHA ruling, they didn’t even ADDRESS the obvious issues that (i) the COVID vaccine is persuasively demonstrated to have little-to-no impact (arguably even an adverse impact) on COVID transmissibility, and made questionable (at best, actually; for supposedly trained medical practitioners/researcher, I would argue objectively STUPID assumptions about mask effectiveness), (ii) they didn’t even account for OTHER PORTENTIAL IMPACTS/CAUSES (like, for example, “no bail; catch and release” prosecution policies).

    4. I won’t even get into the absurdity of their “math”, “assumptions”, or “model” – they are too embarrassing for me to even grant the respect of a rebuttal.

    5. They cite “sources” that are OBJECTIVELY (i) biased, (ii) not scientifically/medically rigorous, and (iii) they ignore other, at least equally credible, contrary sources. If I were grading this as a law school or statistics professor (can’t speak as to medical professor) as a final paper? I’d would have flunked their sorry @$$es out, and recommended that the recruiting officer be fired, as well.

    This is (and I realized this sounds hyperbolic; so be it) probably the MOST pathetic, ham-handed, incompetent, infantile piece of alleged “professional/scientific” “research” is have ever had the misfortune to analyze. I can’t say that they actually faked anything (but c.f., Bellesisles – no telling what a Leftist propagandist will stoop to), but, short of that, there is literally NOTHING in this study that is even worthy of discussion or debate.

    The authors should be tarred, feathered, and ridden out of town on a rail. “So, tell us, LampOfDiogenes, what do you REALLY think? Don’t hold back!” You don’t even want to know.

    • neiowa,

      Apparently, they are fairly adept at organizing election fraud. Apparently, there are precincts in the US that had more “votes” than actual voting-age individuals. Curious, isn’t it??

      They are only efficient/effective when it suits their purposes (and even that, ineptly). When it suits them to be incompetent idiots, THAT they excel at.

        • MAXX,

          It used to be “Hey, Sailor”; now, apparently, it’s “Hey, little boy!”. The “gender fluid” Left argues vehemently that “gays aren’t pedophiles” . . . and then goes nuts if you try to limit their access to little kids. I would have respect for their honesty (if nothing else) if they would just admit that their goal is to diddle little kids. Having to lie about it just proves how dishonest they are.


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