14 Ohio opinions name it 2 courts 2011–2026 9 in the last five years
The cases below were cited by Ohio 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 |
|---|---|---|
United States v. Erick Williamsgreen2 sentences2024See Williams, 113 F.4th at 656 (“Classifying 6 The Skaggs court also rejected the defendant’s Second Amendment challenge on the ground that “history and tradition . . . support the legislature’s power to restrict the Second Amendment right of drug users, alcoholics, or the mentally ill to carry firearms.” Skaggs, 2024-Ohio-4781 , at ¶ 31 (5th Dist.). 2024See Williams, 113 F.4th at 656 (“Classifying 6 The Skaggs court also rejected the defendant’s Second Amendment challenge on the ground that “history and tradition . . . support the legislature’s power to restrict the Second Amendment right of drug users, alcoholics, or the mentally ill to carry firearms.” Skaggs, 2024-Ohio-4781 , at ¶ 31 (5th Dist.). | 2 | 3 |
District of Columbia v. Hellergreen2 sentences2026Ultimately, the Court concluded that “[o]ur tradition of firearm regulation allows the Government to disarm individuals who present a credible threat to the physical safety of others.” Id. at 700 . {¶ 36} The Bruen and Rahimi decisions set forth a two-step framework for analysis of a Second Amendment challenge to a firearm regulation: (1) whether the plain text of the Second Amendment covers the act or course of conduct and (2) if it does, whether the government can demonstrate that the regulation is consistent with the principles that underpin the nation’s historical tradition of firearm regu 2026Ultimately, the Court concluded that “[o]ur tradition of firearm regulation allows the Government to disarm individuals who present a credible threat to the physical safety of others.” Id. at 700 . {¶ 36} The Bruen and Rahimi decisions set forth a two-step framework for analysis of a Second Amendment challenge to a firearm regulation: (1) whether the plain text of the Second Amendment covers the act or course of conduct and (2) if it does, whether the government can demonstrate that the regulation is consistent with the principles that underpin the nation’s historical tradition of firearm regu | 1 | 4 |
United States v. Connellygreen2 sentences2026See, e.g., United States v. Connelly, 117 F.4th 269, 274 (5th Cir. 2024); Williams, 113 F.4th at 648 . 4. 2026See, e.g., United States v. Connelly, 117 F.4th 269, 274 (5th Cir. 2024); Williams, 113 F.4th at 648 . 4. | 1 | 1 |
Arnold v. City of Clevelandgreen1 sentence2026In Arnold v. Cleveland, 67 Ohio St.3d 35, 48 (1993), the Ohio Supreme Court held that Article I, Section 4 of the Ohio Constitution requires that any law governing firearms be “a reasonable regulation, promoting the welfare and safety of the people.” The Court has never walked back this view of the Ohio Constitution, and Bruen, however it may have affected federal law, has no bearing on the meaning of our state constitution. | 1 | 1 |
State v. Jenkinsgreen1 sentence2025See Jenkins, 2024-Ohio-1094 , at Assignment of Error I (5th Dist.). | 1 | 1 |
State v. Carnes (Slip Opinion)green1 sentence2024See Carnes at ¶ 20 (declining to reach Second Amendment issue). {¶95} Because this is an as-applied challenge, we do not decide that a juvenile delinquency adjudication may never be probative of whether an individual poses a danger to the community. | 1 | 1 |
Greenhills Home Owners Corp. v. Village of Greenhillsgreen2 sentences2014However, “such necessity is 5 absent where other issues are apparent in the record which will dispose of the case on its merits.” Greenhills Home Owners Corp. v. Village of Greenhills, 5 Ohio St.2d 207, 212 (1966). {¶9} The Second Amendment to the United States Constitution provides: “A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.” {¶10} In Heller, the United States Supreme Court “considered a Second Amendment challenge to three ordinances enacted by the District of Columbia, which (1) totally ba 2014However, “such necessity is 5 absent where other issues are apparent in the record which will dispose of the case on its merits.” Greenhills Home Owners Corp. v. Village of Greenhills, 5 Ohio St.2d 207, 212 (1966). {¶9} The Second Amendment to the United States Constitution provides: “A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.” {¶10} In Heller, the United States Supreme Court “considered a Second Amendment challenge to three ordinances enacted by the District of Columbia, which (1) totally ba | 1 | 1 |
Heller v. District of Columbiagreen2 sentences2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano 2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano | 1 | 1 |
United States v. Marzzarellagreen2 sentences2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano 2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano | 1 | 1 |
United States v. Chestergreen2 sentences2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano 2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano | 1 | 1 |
Rhonda Ezell v. City of Chicagogreen2 sentences2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano 2012See, e.g., Heller v. District of Columbia, 670 F.3d 1244, 1257-1258 (D.C.Cir.2011) (registration requirements subject to intermediate scrutiny because they do not prevent an individual from possessing a firearm); see also Ezell v. Chicago, 651 F.3d 684, 708 (7th Cir.2011) (concluding that the city’s ban on firing ranges was subject to “a more rigorous showing than [intermediate scrutiny], * * * if not quite ‘strict scrutiny[]’”); United States v. Chester, 628 F.3d 673, 682-683 (4th Cir.2010) (applying intermediate scrutiny to statute prohibiting gun possession by person convicted of misdemeano | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
New York State Rifle & Pistol Assn., Inc. v. Bruen
green
2 sentences2025The Rahimi Court confirmed, “Why and how the regulation burdens the right are central to the Second Amendment inquiry.” Id. 2025The Rahimi Court confirmed, “Why and how the regulation burdens the right are central to the Second Amendment inquiry.” Id. | 3 | 2024–2025 |
State v. Weber (Slip Opinion)
green
2 sentences2026State v. Weber, 2020-Ohio-6832, ¶ 47 . 2026State v. Weber, 2020-Ohio-6832, ¶ 47 . | 1 | 2026–2026 |
State v. Thacker
green
2 sentences2025We recently had occasion to consider a Second Amendment challenge to a different provision of the same statute in Thacker, 2024-Ohio-5835 (1st Dist.). 2025We recently had occasion to consider a Second Amendment challenge to a different provision of the same statute in Thacker, 2024-Ohio-5835 (1st Dist.). | 1 | 2025–2025 |
McDonald v. City of Chicago
green
2 sentences2023According to Coran, “[n]ot reaching the merits of his claim * * * would arguably tend to relegate the Second Amendment right claimed to ‘a second-class right, subject to an entirely different body of rules than the other Bill of Rights guarantees that [the United States Supreme Court has] held to be incorporated into the Due Process Clause.’ ” Id., quoting McDonald v. Chicago, 561 U.S. 742, 780 , 130 S.Ct. 3020 , 177 L.Ed.2d 894 (2010). -8- {¶ 18} We do not agree with Coran that the “rights and interests involved” in this case warrant exercising our discretion to consider Coran’s waived consti 2023According to Coran, “[n]ot reaching the merits of his claim * * * would arguably tend to relegate the Second Amendment right claimed to ‘a second-class right, subject to an entirely different body of rules than the other Bill of Rights guarantees that [the United States Supreme Court has] held to be incorporated into the Due Process Clause.’ ” Id., quoting McDonald v. Chicago, 561 U.S. 742, 780 , 130 S.Ct. 3020 , 177 L.Ed.2d 894 (2010). -8- {¶ 18} We do not agree with Coran that the “rights and interests involved” in this case warrant exercising our discretion to consider Coran’s waived consti | 1 | 2023–2023 |
State v. May
green
1 sentence2023According to Coran, “[n]ot reaching the merits of his claim * * * would arguably tend to relegate the Second Amendment right claimed to ‘a second-class right, subject to an entirely different body of rules than the other Bill of Rights guarantees that [the United States Supreme Court has] held to be incorporated into the Due Process Clause.’ ” Id., quoting McDonald v. Chicago, 561 U.S. 742, 780 , 130 S.Ct. 3020 , 177 L.Ed.2d 894 (2010). -8- {¶ 18} We do not agree with Coran that the “rights and interests involved” in this case warrant exercising our discretion to consider Coran’s waived consti | 1 | 2023–2023 |
Troxel v. Granville
green
2 sentences2020It involved a parent’s claim that Ohio’s nonparental-visitation statutes “unconstitutionally infringe on a parent’s fundamental right to make decisions concerning the care, custody, and control of his or her child,” id. at ¶ 13, a right that is protected by the Due Process Clause of the Fourteenth Amendment of the United States Constitution, id. at ¶ 40, citing Troxel v. Granville, 530 U.S. 57, 66 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), and Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 , 372, 696 N.E.2d 201 (1998). 2020It involved a parent’s claim that Ohio’s nonparental-visitation statutes “unconstitutionally infringe on a parent’s fundamental right to make decisions concerning the care, custody, and control of his or her child,” id. at ¶ 13, a right that is protected by the Due Process Clause of the Fourteenth Amendment of the United States Constitution, id. at ¶ 40, citing Troxel v. Granville, 530 U.S. 57, 66 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), and Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 , 372, 696 N.E.2d 201 (1998). | 1 | 2020–2020 |
Zivich v. Mentor Soccer Club, Inc.
green
2 sentences2020It involved a parent’s claim that Ohio’s nonparental-visitation statutes “unconstitutionally infringe on a parent’s fundamental right to make decisions concerning the care, custody, and control of his or her child,” id. at ¶ 13, a right that is protected by the Due Process Clause of the Fourteenth Amendment of the United States Constitution, id. at ¶ 40, citing Troxel v. Granville, 530 U.S. 57, 66 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), and Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 , 372, 696 N.E.2d 201 (1998). 2020It involved a parent’s claim that Ohio’s nonparental-visitation statutes “unconstitutionally infringe on a parent’s fundamental right to make decisions concerning the care, custody, and control of his or her child,” id. at ¶ 13, a right that is protected by the Due Process Clause of the Fourteenth Amendment of the United States Constitution, id. at ¶ 40, citing Troxel v. Granville, 530 U.S. 57, 66 , 120 S.Ct. 2054 , 147 L.Ed.2d 49 (2000), and Zivich v. Mentor Soccer Club, Inc., 82 Ohio St.3d 367 , 372, 696 N.E.2d 201 (1998). | 1 | 2020–2020 |
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.