New Jersey Association seeks to sue Garden State over Mr. & Mrs. Smith-style training mandate

Matt Sayles

If you’re interested in participating in a challenging marksmanship program that’ll tax your tactical abilities, then we’ve got something for you. While you could go to one of the many top-of-the-line and state-of-the-art training destinations to challenge yourself and get in some time behind the trigger, don’t bother. The New Jersey State Police has chartered a program that’s for those seeking a real challenge. Unfortunately, this challenge is not a joke, but it’s what the state has decided to implement as a training requirement to get a permit to carry. The Association of New Jersey Rifle and Pistol Clubs just asked to have their federal challenge to the law that put this training into effect reopened in the New Jersey Federal District Court because of the onerous mandate. 


The newly rolled out training requirements in order to get a permit to carry seem like exactly what’s described above. An authoritative and challenging course of fire that an expert would be looking to use to cut their teeth further, is not what Mr. and Mrs. New Jersey should have to do in order to exercise a constitutional right. Rather than New Jersey be lock-step with the rest of the country that has reasonable training mandates, they’d prefer to force everyday people to be able to rise to a training standard that Mr. and Mrs. Smith would have to.

Sounds hyperbolic, but consider attorney Evan Nappen’s explanation of what the training requirement is for nearly all current and future permit to carry holders. Nappen refers to the training as “New Jersey’s ‘John Wick’ Carry Training Mandate.”

A new and much more difficult level of shooting proficiency is now required for citizens in New Jersey who wish a obtain a Permit to Carry a Handgun or continue to keep their Permit to Carry a Handgun. The new requirements demand timed firing from concealed holsters. Kneeling position shooting and accurately shooting at 25 yards are also incorporated into the course. It is hard to envision citizen self-defense scenarios justifying the use of deadly force at 25 yards! There are no exceptions for physically handicapped people. The new requirements are basically the same requirements utilized for retired police officers to get their New Jersey RPO handgun carry card. This means that any citizen who wishes to exercise their Second Amendment rights must now have the same skill level of proficiency as a veteran law enforcement officer who has trained and qualified with firearms for years!

If a person wants a Drivers License, should they be required to qualify as a NASCAR Racer before receiving it? Yet, driving is not a Constitutional right, but carrying a gun is one. Harsh requirements are not permitted for the exercise of Constitutional rights. New Jersey is using a variation out of the racist playbook of Southern Democrats who tried to stop Blacks from voting by demanding poll taxes and literacy tests. The anti-Constitutional rights NJ Democrats have done the same thing here for the exercise of Second Amendment rights by all citizens with the passage of the Murphy “Carry Killer” Anti-Civil Rights law.


Nappen points out something we’ve all been saying since last year, and that’s Governor Phil Murphy – as well as many other executives, lawmakers, and judges all over the blue states of the U.S.- have been approaching the NYSRPA v. Bruen decision in the same manner southern leaders treated Blacks during the antebellum Jim Crow period of our country and a post-Brown v. Board of Education United States.

The anti-civil liberty pinkos have jumped the shark when it comes to regulation, and the new training standard is a bridge too far. Consider footnote #9 from NYSRPA:

That said, because any permitting scheme can be put toward abusive ends, we do not rule out constitutional challenges to shall-issue regimes where, for example, lengthy wait times in processing license applications or exorbitant fees deny ordinary citizens their right to public carry.

The training would constitute an abusive end according to the opinion. Not only are the training requirements beyond what would be considered “designed to ensure only that those bearing arms in the jurisdiction are, in fact, ‘law-abiding, responsible citizens,’” not consistent with the footnote, as a sidebar, the newly instituted fees fit that bill as well. Those fees quadrupled the price of a permit to carry and the state also implemented a raise that’s more than ten times more for permits to purchase a handgun. When Governor Phil Murphy pushed his idiotic lackey Assemblyman Joe Danielsen to introduce the bill with those requirements, it was 100% to act as a way to “deny ordinary citizens their right to public carry.”


On July 26, 2023, ANJRPC requested that the federal suit be reopened in order to challenge this garbage of a training mandate.

ANJRPC has taken initial steps to overturn the NJ State Police training requirements that were issued last week. Those requirements absurdly compel ordinary citizens to meet the same training requirements as members of law enforcement in order to obtain a carry permit. Requiring average citizens to meet police level training requirements is being mandated purely to make it much harder for the average citizen to qualify to obtain a carry permit in the first place. Additionally, many of those requirements relate solely to law enforcement functions having nothing to do with the exercise of self-defense rights by average citizens.

ANJRPC counsel Dan Schmutter has asked the lower federal court in the carry-killer lawsuit to reopen the case to assert new claims to overturn the new training regulations. CLICK HERE and scroll down to item #30 to see a copy of those papers. Assuming the request is granted, additional papers detailing the claims will be filed (and we will issue another alert at that time).

In a future alert, ANJRPC will be seeking gun owners interested in joining the lawsuit if they meet certain criteria which will be specified. Please watch for that alert.

If you are not already subscribed to these free email alerts, click here to sign up — there will be critical updates and alerts coming in the near future.

If you want to contribute to this next phase of the carry-killer lawsuit click here to make a donation.


The request for the federal court to reopen the case did not sit idle, as Judge Marie Bumb granted ANJRPC’s request not long after it was filed the same day.

The State of New Jersey can try to argue a public safety and welfare approach all they want, and while that might appeal to the sensibilities of some people, their entire tactic is going to be an affray with NYSRPA’s orders. The interest balance tests of yesteryear are out the window, and New Jersey is going to have a hard time justifying why an average citizen needs to have the exact same level of proficiency with a firearm that a police officer would be required to have. The qualification standard kind of throws to the wind the state’s argument that police officers and retired police officers are not barred from the same sensitive locations as civilian permit to carry holders because of their level of training. Is the New Jersey State Police trying to make our arguments for us? 

What’s going to happen next? Who knows. But this is getting spicy for sure. Will there be a temporary restraining order put in place after an amended brief is filed? I hope so. But in the meantime, those that have permits to carry issued after a certain date and those that wish to obtain a permit to carry, best start training. Current permit holders have to have the new qualifications and training done by October. We’ll be watching the progress of and reporting on this new challenge to New Jersey’s “carry killer” law, as well report on the forthcoming arguments at the 3rd Circuit Court of Appeals on October 25th, 2023.


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