Lawyers urge Illinois courts to follow D.C. ruling invalidating bans on magazines holding over 10 rounds

A new appellate decision in Washington reopens debate over magazine-capacity limits nationwide

A recent ruling by the District of Columbia Court of Appeals invalidating Washington’s ban on firearm magazines capable of holding more than 10 rounds is being cited by gun-rights advocates in Illinois as they press federal courts to revisit Illinois’ own capacity restrictions.

The D.C. case arose from the prosecution of Tyree Benson, who was convicted after a bench trial on stipulated facts stemming from possession of a handgun equipped with a 30-round magazine. The court’s decision, issued March 5, 2026, reversed and vacated Benson’s convictions not only for possessing a prohibited “large capacity ammunition feeding device,” but also for related offenses tied to the District’s regulatory scheme, including possession of an unregistered firearm, carrying a pistol without a license, and unlawful possession of ammunition.

What the D.C. court decided—and what it did not

The D.C. Court of Appeals framed its analysis under the Supreme Court’s modern Second Amendment framework, focusing on whether the regulated item is protected “arms,” whether it is in common use for lawful purposes, and whether the government can point to a historical tradition supporting the restriction. The majority concluded that magazines over 10 rounds fall within Second Amendment protection and that the District’s categorical ban conflicted with the governing test.

The court also drew a distinction within D.C. law between detachable magazines and other feeding devices. It stated its holding addressed the ban on magazines over 10 rounds, not separate prohibitions covering belts, drums, or feed strips.

The decision adds to an already fragmented national landscape, with different courts reaching different outcomes on similar capacity limits under the same Supreme Court standard.

Illinois: capacity limits embedded in the Protect Illinois Communities Act

Illinois’ large-capacity magazine restrictions are part of the Protect Illinois Communities Act (PICA), enacted in January 2023. The law’s magazine provisions operate alongside limits on certain semiautomatic firearms and related items, and they have been the subject of extensive litigation in state and federal courts.

In federal court, a Southern District of Illinois ruling issued in November 2024 permanently enjoined key parts of PICA, including the large-capacity magazine restrictions. That injunction, however, was quickly stayed by the U.S. Court of Appeals for the Seventh Circuit, leaving the law enforceable while appeals proceed.

Why advocates say the D.C. ruling matters in Illinois

Lawyers urging Illinois courts to apply the D.C. court’s reasoning point to the shared constitutional test used in post-2022 Second Amendment challenges and argue that a finding that commonly used magazines are protected “arms” should inform how Illinois’ limits are evaluated. Illinois officials, meanwhile, have continued defending PICA in ongoing proceedings, with the state’s position centered on the constitutionality of regulating weapons and components viewed as increasing lethality.

What to watch next

• Whether the Seventh Circuit issues a merits decision on Illinois’ magazine limits and related PICA provisions.
• Whether the conflicting outcomes across jurisdictions deepen pressure for U.S. Supreme Court review.
• How courts handle the practical overlap between magazine limits and broader licensing and possession rules, a key issue highlighted by the D.C. case.

For now, the D.C. ruling is limited to the District’s legal framework, while Illinois’ restrictions remain in force during the federal appeals process.