On December 8, 2023, the Second Circuit struck down as unconstitutional the provision of New York’s Concealed Carry Improvement Act prohibiting the carrying of licensed concealed firearms onto another person’s private property that is open to the public absent clear signage or the express consent by the property owner. As a result, the default rule will be that individuals are permitted to carry licensed firearms onto private property open to the public unless the property owner expressly prohibits such carriage. Property owners in New York will need to consider whether they wish to post signage concerning the carrying of firearms on their property in light of this decision.