In 2022, the state of Oregon passed a ballot measure which banned so-called "high-capacity magazines" which it defines as any magazine or loading device which can hold more than ten rounds. Despite the ballot measure only narrowly winning by <1.5%, no ballot measure or any other law may violate the Constitution. Oregon Measure 114 is in clear violation of the Second Amendment since a magazine is a part of what constitutes a protected and bearable arm. One of the plaintiffs, Joseph Arnold, has a firearm which only can accept an 11-round magazine. Under this measure, Arnold may not lawfully carry his firearm. On behalf of Arnold, the other plaintiffs, and all citizens in the state of Oregon, GOA and GOF filed a Preliminary Injunction Motion to ensure this law does not go into effect.