Firearm Law &  Commentary
by Victor Quilici, ISRA Counsel


McDonald v. City of Chicago
561 U.S. ____ (2010)

July 3, 2010

In a 5-4 landmark decision, the United States Supreme Court followed its ground-breaking ruling in District of Columbia v. Heller, 554 U.S. _____, and, in reversing the Seventh Circuit’s affirmation of a District Court’s holding denying Petitioner’s 2nd Amendment arguments against municipal firearms bans by the City of Chicago and Oak Park, held that the Second Amendment is a fundamental right and is incorporated against the states under the 14th Amendment of the U.S. Constitution. The case has been remanded (returned) to the 7th Circuit Court of Appeals for reconsideration pursuant to the decision by the U.S. Supreme Court.

While the majority of the Court deciding in favor of McDonald held that the 2nd Amendment is incorporated by the Due Process clause of the 14th Amendment, Justice Thomas took one of the roads argued by Petitioners’ counsel, which made some believe that the Court overruled the Slaughterhouse and Cruikshank decisions, and that the “privileges and immunities” clause of the Constitution was the basis for Second Amendment incorporation. Nevertheless, Justice Thomas’ concurring opinion, together with that of Justice Scalia’s, added to the majority five votes needed to decide favorably for the Petitioners. Attorney Alan Gura, who was counsel in the Heller case, successfully represented McDonald, and other individual petitioners as well as the Illinois State Rifle Association and the Second Amendment Foundation. Attorney Gura has certainly made his mark in history.

A Supreme Court 5-4 decision raises a red flag as to why four of the Justices could not see what freedom-loving Americans have believed for centuries, and which the founding fathers of our nation perceived as a fundamental, inalienable right deeply rooted in our nation’s history, and implicit in the concept of ordered liberty. That right, most scholars have believed, existed before the passage of the 2nd Amendment. The majority made frequent references to the pre-existing right of self-defense, which is the back-bone of the Second Amendment, and there is much to be said about the majority’s dissection of the strained arguments posed by Justice Stevens.

The Majority’s caveat re-affirmation of the position it took in the District of Columbia v. Heller case that various firearm restrictions, including the prohibition of possession of firearms by felons or the mentally ill, and those laws affecting the commercial sale of firearms, and those imposing restrictions regarding the carrying of firearms in sensitive areas such as government buildings and the like, still apply, raises another red flag. Coupled with the fact that four of the Justices, and most assuredly their successors, will continue to take an opposing stand to applications of the principles set forth by the majority in McDonald, these restrictions can be stretched and broadened to a point where more of our rights are suppressed. While all agree that keeping firearms out of the hands of felons, the mentally ill, and away from sensitive places such as courtrooms, it is the interpretation of those restrictions that require our constant alertness and strict scrutiny to ensure that those restrictions are not employed in an arbitrary and discriminatory manner so as to further alienate our rights

It will be interesting to learn how anti-gun advocates and some courts will interpret the McDonald majority’s reference that the “fundamental right guarantee is fully binding on the states and thus limits (but by no means eliminates) their ability to devise solutions to social problems that suit local needs and values.” Also, quoting from the 38 states’ and amicus brief of the State of Texas, the Court noted that “state and local experimentation with reasonable firearms regulations will continue under the Second Amendment.”

Repeatedly, we have seen cases setting forth a basic principle of law abused by law enforcement authorities and ignored by some courts to a point of ludicrousness. Classic examples are registration requirements imposed to such a degree in some anti-gun municipalities such as Chicago, and various states, that the real aim is to defeat the thrust of 2nd and 14th Amendment protections. Many Courts also have repeatedly ignored the protections afforded under the 4th and 14th amendments by upholding invalid searches and seizures. Fortunately, many of those decisions have been cured on appeal to higher courts, but not always. That, of course, is a matter ISRA has addressed in cases such as People v. Diggins, and by its constant watch-guard of legislation by its lobbyists in Springfield.

ISRA is currently backing two cases that will assuredly be addressed by the Courts pursuant to the holdings in McDonald—that is, the pending State Supreme Court case of Wilson v. Cook County (addressing an assault weapon ban aimed at confiscating guns normally used for hunting and target shooting), and City of Chicago v. Patrick ( a confiscation of 276 firearms from a collector).

All should be prepared for a continued fight in the trenches regarding the preservation of your fundamental inalienable rights, especially in light of the new anti-gun ordinance enacted by the City of Chicago. Now, more than ever, is the time to send your donations to ISRA so that it may continue to fight for the preservation of your rights.
 


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