According to the NRA-ILA, Garland played a key role in several decisions intended to restrict gun rights to American citizens.

In 2007, Garland voted to allow Washington D.C. a second chance to allow its handgun ban to be upheld after a three-judge panel struck it down. Three years earlier he voted against rehearing a Second Amendment case, Seegers v. Gonzales, where the plaintiff challenged the city's firearm ban.

Additionally, in 2000, Garland voted in favor of the federal government's proposal to keep Americans' private information via gun purchase background checks despite federal laws banning national firearm registration and mandating the destruction of these records.