By Natalie Szymanski
BUFFALO, N.Y. — When New York asked a federal judge in Buffalo to keep its ban on civilian body armor purchases alive, it ran into a standard John L. Sinatra Jr. has applied to the state’s gun laws since 2022: show a historical tradition of similar regulation, or the law falls.
Sinatra, a U.S. District Judge for the Western District of New York who earned both of his degrees at the University at Buffalo, ruled on Oct. 21 that the 2022 ban violates the Second Amendment. The Buffalo Chronicle reported on the decision last week. This profile looks at the judge behind it, his UB roots and the legal approach that now runs through several of his biggest cases.
“Indeed, body armor is an ‘Arm’ protected by the plain text of the Second Amendment,” Sinatra wrote in the 47-page decision and order in Heeter v. James. “As such, regulation in this area is permissible only if the State demonstrates that the new enactment is consistent with the Nation’s historical tradition of sufficiently analogous regulations. New York fails that test.”
Two UB degrees and a Buffalo law practice
Sinatra was born in Buffalo in 1972. According to his Federal Judicial Center biography, he earned a bachelor’s degree from the State University of New York at Buffalo in 1993 and a law degree from what is now the University at Buffalo School of Law in 1996. His Wikipedia entry, which cites his former firm and his Senate questionnaire, says he graduated magna cum laude from UB and cum laude from the law school.
After law school, he clerked at the New York Court of Appeals from 1996 to 1998. He then spent nine years practicing in Cleveland with Jones Day and served as senior counsel at the U.S. Department of Commerce from 2007 to 2008, according to the Second Circuit library’s history of the Western District. He came home to practice at Hodgson Russ in Buffalo from 2008 until he joined the bench in 2019.
His Senate questionnaire lists membership in the Federalist Society since 1993, the year he finished at UB.
A Trump nominee with Schumer’s backing
President Donald Trump first nominated Sinatra in May 2018 to the seat vacated by Judge William M. Skretny. The nomination came with the support of New York’s senior senator, Democrat Chuck Schumer, which was unusual in a polarized confirmation era.
“This nomination was the result of a sound, collaborative and bi-partisan process that produced a well-respected and legally-qualified choice with broad bi-partisan support throughout Buffalo and the Western New York community,” Schumer spokesman Jason Kaplan said in a May 2018 statement.
That first nomination expired at the end of the congressional session, and Trump sent it back in 2019. The Senate confirmed Sinatra on Dec. 4, 2019, by a 75–18 vote, according to his Wikipedia biography. He received his commission the next day.
“New York fails that test,” again
The body armor decision repeats a sentence Sinatra wrote four years ago. In October 2022, months after the U.S. Supreme Court’s New York State Rifle & Pistol Association v. Bruen decision, he temporarily blocked a provision of New York’s new concealed-carry law that made it a felony for license holders to carry a gun in a place of worship.
“In Bruen, the Court made the Second Amendment test crystal clear: regulations in this area is permissible only if the government demonstrates that the regulation is consistent with the Nation’s historical tradition of sufficiently analogous regulations,” Sinatra wrote then, CNN reported. He added: “New York fails that test.”
“In sum, the Nation’s history does not countenance such an incursion into the right to keep and bear arms across all places of worship across the state,” he wrote in that case, brought by two church leaders.
The Second Circuit’s own history of the district lists two other 2022 rulings among his noteworthy cases. In Christian v. Nigrelli, he blocked a provision that made it a felony for license holders to carry on private property open to the public without the owner’s express consent. In Spencer v. Nigrelli, he blocked the place-of-worship ban on both First and Second Amendment grounds. On appeal, the U.S. Court of Appeals for the Second Circuit affirmed the Christian injunction on Second Amendment grounds and the Spencer injunction on free-exercise grounds.
The same history notes a 2020 case, Hund v. Cuomo, in which Sinatra blocked a COVID-19 rule that let bars and restaurants offer incidental live music but barred advertised, ticketed shows. The case was later sent back from the Second Circuit, and the injunction was vacated by agreement of the parties, according to the court history.
How he read the history this time
New York’s lawyers made a serious historical case. The state argued that body armor “is not an ‘Arm’ as the term would have been commonly understood in 1791 or 1868,” and that “at most, body armor is better understood as a tactical accessory to firearms,” according to the ruling’s summary of its briefs. It pointed to English law, including the medieval Statute of Northampton, which barred people from going or riding “armed” in fairs and markets.
Gun-safety groups backed the state. In an amicus brief, Brady, Giffords Law Center and Everytown for Gun Safety argued that body armor “is frequently used by mass shooters to extend and maximize the terror of their violent acts and insulate them from being stopped by law enforcement and others.” The law was passed weeks after the May 2022 Tops Friendly Markets massacre on Jefferson Avenue, where the gunman wore armor.
Sinatra was not persuaded. He wrote that the state could not identify “a single regulation on body armor post-ratification” and called the ban “a novel outlier unsupported by any mainstream tradition.” He said the state had relied on “cherry-picked prohibitions from across the span of Western Civilization.”
He also weighed the market. Citing the plaintiffs’ estimates, he noted that more than 93,000 units of body armor were bought in 2025, and he wrote that “49 states do not ban body armor.” He made clear the ruling leaves in place New York’s separate crime of wearing body armor while committing a violent felony with a gun.
The plaintiffs, the Firearms Policy Coalition and members Benjamin Heeter and Joseph Wurtenberg, called it a first. “We said from the beginning that this immoral ban was absurd and unconstitutional,” FPC President Brandon Combs said in a statement. The office of Attorney General Letitia James said it was reviewing the decision, Courthouse News Service and Syracuse.com reported.
A judge who also guards the process
The case file shows Sinatra’s attention to procedure. About two weeks after the lawsuit was filed on July 1, 2024, the state moved to have it reassigned, and he denied the motion in a text order on the docket. He agreed with the state that the case was unrelated to his earlier Second Amendment cases and wrote that he had instructed the clerk’s office to assign it through the district’s normal random process.
“In short, the Court forced a random assignment, and then (several times) confirmed that this, in fact, occurred,” he wrote.
He also gave the state something it asked for. Although he wrote that he “disagrees that the State is likely to succeed on the merits of any appeal,” he granted a 14-day stay so New York could go to the Second Circuit. He quoted Chief Justice John Roberts: “any time a State is enjoined by a court from effectuating statutes enacted by representatives of its people, it suffers a form of irreparable injury.”
As of CourtListener’s most recent update of the docket on Oct. 25, no notice of appeal appeared. If the state appeals, the Second Circuit in Manhattan will have the next word.
The Buffalo Chronicle sought comment from Judge Sinatra’s chambers through the clerk of the U.S. District Court for the Western District of New York for this story. Federal judges generally do not comment on their rulings. This article will be updated with any response.
John L. Sinatra Jr. at his Aug. 1, 2018, Senate Judiciary Committee nomination hearing. Photo: U.S. Senate Judiciary Committee / Wikimedia Commons, public domain.
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