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13 Illinois opinions name it 2 courts 2018–2025 3 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
New York State Rifle & Pistol Assn., Inc. v. Bruengreen2 sentences2025Id. at 2. ¶ 48 In Aguilar and Mosley, our supreme court concluded that the second step, the means-end scrutiny analysis, need not be addressed because age-based restrictions fell outside the scope of the second amendment. 2023Bruen, 597 U.S. at ___ , 142 S. Ct. at 2127, 2131 . | 2 | 2 |
District of Columbia v. Hellergreen2 sentences2025We briefly trace this evolution and explain why, notwithstanding these changes, we continue to find that the restriction on operable guns in public parks does not violate the second amendment. ¶ 16 A. Second-Amendment Challenges Under Heller and McDonald ¶ 17 In District of Columbia v. Heller, 554 U.S. 570, 595 (2008), the United States Supreme 4 Court held that the second amendment protects an individual’s right to keep and bear arms for self-defense. 2020See Heller, 554 U.S. at 625 . | 2 | 2 |
Rhonda Ezell v. City of Chicagogreen2 sentences2023“If history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected,’ ” then courts proceeded to the second step— conducting a means-end analysis, “weighing the severity of the regulation against the ends the government sought to achieve.” Id. (quoting Ezell v. City of Chicago, 651 F.3d 684, 703 (7th Cir. 2011)). ¶ 37 Recently, however, in Bruen, the United States Supreme Court rejected the two-step approach as “one-step too many” and condemned any means-end analysis in the second amendment context. 2019“Under this approach, the second step of the inquiry requires the court to examine the strength of the government’s justifications for restricting certain firearm activity by evaluating the restriction the government has chosen to enact and the public-benefits ends it seeks to achieve. [Citations.] *** [A] severe burden on the core Second Amendment right of armed self-defense will require an extremely strong public-interest justification and a close fit between the government’s means and its end. [Citation.] However, laws restricting activity lying closer to the margins of the Second Amendment | 1 | 6 |
Illinois Ass'n of Firearms Retailers v. City of Chicagogreen2 sentences2018Id.; Illinois Ass’n of Firearms Retailers v. City of Chicago, 961 F. Supp. 2d 928, 934 (N.D. 2018Id. ; Illinois Ass'n of Firearms Retailers v. City of Chicago , 961 F.Supp.2d 928 , 934 (N.D. | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Chairez
green
2 sentences2020“Thus, the heightened means-end inquiry is a sliding scale that is neither fixed nor static.” Chairez, 2018 IL 121417, ¶ 35 . ¶ 56 Under the first step of the analysis, as set forth in In re Jordan G., we must at least assess whether plaintiff has an arguable claim that the FOID Act is inconsistent with the historical understanding of the scope of the rights guaranteed by the second amendment. 2018Chairez , 2018 IL 121417 , ¶ 35, 423 Ill.Dec. 69 , 104 N.E.3d 1158 . | 3 | 2018–2020 |
Michael Moore v. Lisa Madigan
green
2 sentences2019Thus, a substantial curtailment of the right of armed self-defense requires a greater showing of justification than merely that the public might benefit on balance from such a curtailment." (Emphasis omitted.) Id. ¶ 43 (citing Moore v. Madigan , 702 F.3d 933 , 940 (7th Cir. 2012) ). "[C]onversely, when a state bans guns merely in particular places, such as public schools, a person can preserve an undiminished right of self-defense by not entering those places; since that's a lesser burden, the state doesn't need to prove so strong a need. [Citation.]" (Internal quotation marks omitted.) Id. ¶ 2019Thus, a substantial curtailment of the right of armed self-defense requires a greater showing of justification than merely that the public might benefit on balance from such a curtailment." (Emphasis omitted.) Id. ¶ 43 (citing Moore v. Madigan , 702 F.3d 933 , 940 (7th Cir. 2012) ). "[C]onversely, when a state bans guns merely in particular places, such as public schools, a person can preserve an undiminished right of self-defense by not entering those places; since that's a lesser burden, the state doesn't need to prove so strong a need. [Citation.]" (Internal quotation marks omitted.) Id. ¶ | 2 | 2019–2019 |
Patrick Atkinson v. Merrick B. Garland
green
1 sentence2023“If history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected,’ ” then courts proceeded to the second step— conducting a means-end analysis, “weighing the severity of the regulation against the ends the government sought to achieve.” Id. (quoting Ezell v. City of Chicago, 651 F.3d 684, 703 (7th Cir. 2011)). ¶ 37 Recently, however, in Bruen, the United States Supreme Court rejected the two-step approach as “one-step too many” and condemned any means-end analysis in the second amendment context. | 1 | 2023–2023 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.