GOAL and Recchia v. Campbell

In recent days, GOAL has received questions and criticism regarding our decision not to financially participate in Recchia v. Campbell. We understand these concerns and believe our members deserve a clear explanation of how and why we make decisions regarding litigation.


GOAL has a responsibility to ensure that every dollar entrusted to us is used effectively, particularly when it comes to the extraordinary costs associated with constitutional litigation.


Since the fall of 2024, GOAL has committed approximately $500,000 to litigation efforts. These resources support two primary objectives: challenging laws we believe violate constitutional rights and defending individuals facing criminal prosecution under Massachusetts firearm laws.

With multiple cases moving through state and federal courts, we must carefully evaluate where our limited financial resources can have the greatest impact. Supporting every potentially worthwhile case is simply not financially sustainable.


GOAL has never opposed Recchia v. Campbell, nor have we ignored the case. We communicated with the plaintiffs, provided opportunities to discuss their legal challenge through the GOAL Podcast and our Partners in Liberty series. Since Recchia brings in the commerce clause through the perspective of a retailer, GOAL facilitated contact with the National Shooting Sports Foundation (NSSF), an organization representing the firearms industry and particularly well-positioned to address issues affecting firearm retailers.


We also instructed our legal counsel to review the pleadings and evaluate the case in relation to GOAL's existing litigation commitments. Following that review, we determined that directly funding another legal challenge involving overlapping constitutional questions would not represent the most responsible allocation of our members' financial contributions.


GOAL has a case of its own in Hanlon v. Campbell, filed August 21, 2025, a federal constitutional challenge to Massachusetts' restrictions on so-called "assault-style firearms." In order to protect resources, GOAL has suspended that case and invested resources in Viramontes (See GOAL’s brief) as it presents the United States Supreme Court with the fundamental question of whether the Second and Fourteenth Amendments protect possession of AR-15-platform and similar semiautomatic rifles. The same non-commerce question that appears in Recchia.


GOAL recognizes the frustration surrounding Massachusetts firearm laws and the understandable desire to challenge every restriction in court. However, effective litigation requires more than a willingness to fight. It requires planning, coordination, experienced legal counsel, and disciplined financial management in coordination with our local and national partners.


Every legal action carries costs, and every dollar committed to one case is a dollar unavailable for another constitutional challenge or the defense of someone facing criminal prosecution. We remain committed to pursuing these legal efforts while exercising the fiscal responsibility our members and supporters have every right to expect.


GOAL will continue to make litigation decisions based on sound legal advice, strategic priorities, and responsible stewardship of the resources entrusted to us by you.