After a few small shootings in September of 2023 in New Mexico, Governor Michelle Lujan Grisham issued an emergency order banning bearing all firearms under the pretense of it being "a public health crisis." Going further than a few token gun control measures, she signed an order banning both concealed and open carry of firearms. Aside from the far-reaching effects of this ban, it also is another attempt to use public health as a pretense for enacting gun control. GOA filed a Temporary Restraining Order (TRO) with Randy Donk, a lawful New Mexico conceal carry permit holder, to stop this order from going into effect.