Counts said that while the U.S. Supreme Court decision did not erase societal and public safety concerns about guns, it had "changed the legal landscape."
"The Second Amendment is not a 'second class right,'" Counts wrote. "No longer can courts balance away a constitutional right."
Quiroz had been indicted in a Texas state court for burglary and later for bail jumping when he attempted in late 2021 to buy a 22-caliber semiautomatic handgun, leading to his federal indictment.
A federal jury on June 23 found him guilty of one count of illegal receipt of a firearm by a person under indictment and one count of making a false statement during the purchase of a firearm.
That same day, the U.S. Supreme Court's 6-3 conservative majority handed down its ruling, which struck down New York's concealed carry law. Quiroz then moved to have the case dismissed, citing that decision.
Counts granted the request, saying a historical survey found "little evidence" that the federal ban "aligns with this Nation’s historical tradition."