The Connecticut Supreme Court has recognized that the Second Amendment extends beyond firearms in State v. DeCiccio, after a Connecticut man moving to Massachusetts was arrested and convicted for transporting a dirk (a kind of long-bladed thrusting dagger used during the tall ship era, as well as ceremonially in certain cultures) and a police baton to his new home.
The court found that both kinds of non-firearms weapons are protected under the Second Amendment.
The court also found that the laws completely banning the transport of these weapons to be unconstitutional.
UCLA law professor Eugene Volokh notes:
The court’s holding that the right to bear arms includes non-firearms, such as knives and batons, is consistent with the bulk of modern precedent on the subject; for other cases striking down bans on such weapons, see State v. Griffin, 47 A.3d 487 (Del. 2012) (knives); People v. Yanna, 824 N.W.2d 241 (stun guns and Tasers); 1986 Fla. Op. Att’y Gen. 2 (stun guns and Tasers); State v. Delgado, 692 P.2d 610 (Or. 1984) (switchblades); State v. Blocker, 630 P.2d 824 (Or. 1981) (billy clubs); State v. Kessler, 614 P.2d 94 (Or. 1980) (billy clubs); Barnett v. State, 695 P.2d 991 (Or. Ct. App. 1985) (blackjacks). But seeCity of Seattle v. Evans (Wash. 2014) (concluding that kitchen knives aren’t constitutionally protected, but not deciding about knives more broadly); State v. Swanton, 629 P.2d 98, 98 (Ariz. Ct. App. 1981) (holding that nunchakus are not arms, because “arms” is limited to “such arms as are recognized in civilized warfare and not those used by a ruffian, brawler or assassin”).
This is only a state case, but like those mentioned by Professor Volokh, they are moving the bar in our direction. Volokh himself is involved in a Massachusetts case, Commonwealth v. Caetano, where he is attempting to make the same argument regarding stun guns and tasers.
Frankly, I’ve always found it bizarre the way that many states closely restrict or even outlaw impact, bladed, chemical and/or energy weapons, while simultaneously recognizing that the Second Amendment applies to firearms.
It’s very unlikely that citizens of Connecticut will start pushing to carry dirks, but it makes a great deal of practical sense to remove laws that ban citizens from being able to protect themselves with folding or fixed-blade knives, ASP-style batons, pepper spray, tasers, or stun guns if they desire to use these arms to protect themselves.