means-ends analysis (Illinois) · Go Syfert
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means-ends analysis in Illinois

6 Illinois opinions name it 1 courts 2023–2025 6 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.

Followed or applied (3)

CaseFollowedCited
Patrick Atkinson v. Merrick B. Garlandgreen
ca7 · 2023 · cited in 4 Illinois opinions naming this issue, 2023–2024
2 sentences

2024However, “[i]f history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected’ courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate -4- No. 1-22-1455 scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.” Brooks, 2023 IL App (1st) 200435, ¶ 67 (citing Atkinson v. Garland, 70 F.4th 1018, 1020 (7th Cir. 2023)). ¶ 12 Recently, in Bruen, the Court condemned the application of any “means-end scrutiny” in the second amendment context.

2024However, “[i]f history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected’ courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.” Brooks, 2023 IL App (1st) 200435, ¶ 67 (citing Atkinson v. Garland, 70 F.4th 1018, 1020 (7th Cir. 2023)). ¶ 13 Recently, in Bruen, the Court condemned the application of any “means-end scrutiny” in the second amendment context.

24
People v. Brooksgreen
illappct · 2023 · cited in 3 Illinois opinions naming this issue, 2024–2024
2 sentences

2024However, “[i]f history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected’ courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate -4- No. 1-22-1455 scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.” Brooks, 2023 IL App (1st) 200435, ¶ 67 (citing Atkinson v. Garland, 70 F.4th 1018, 1020 (7th Cir. 2023)). ¶ 12 Recently, in Bruen, the Court condemned the application of any “means-end scrutiny” in the second amendment context.

2024However, “[i]f history proved inconclusive or suggested that the regulated activity was not ‘categorically unprotected’ courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.” Brooks, 2023 IL App (1st) 200435, ¶ 67 (citing Atkinson v. Garland, 70 F.4th 1018, 1020 (7th Cir. 2023)). ¶ 13 Recently, in Bruen, the Court condemned the application of any “means-end scrutiny” in the second amendment context.

23
New York State Rifle & Pistol Assn., Inc. v. Bruengreen
scotus · 2022 · cited in 4 Illinois opinions naming this issue, 2024–2025
2 sentences

2025Indeed, the Bruen Court made clear when it rejected the means-ends test that applying policy considerations justifying the regulation was “one step too many.” Bruen, 597 U.S. at 19 .

2024“However, ‘[i]f history proved inconclusive or suggested that the regulated activity was not “categorically unprotected,” -5- No. 1-23-0880 courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.’ ” Id. (quoting People v. Brooks, 2023 IL App (1st) 200435, ¶ 67 ). ¶ 17 In Bruen, the Supreme Court adopted a new framework for second amendment claims, holding that “ ‘[w]hen the Second Amendment’s plain text covers an individual

14

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
District of Columbia v. Heller green
scotus · 2008
1 sentence

2024We noted that the Supreme Court has recognized that the second amendment does not confer “ ‘unlimited’ ” rights and that the right to keep and bear arms could be limited based upon the “nature of the arms.” Id. ¶ 14 (quoting Heller, 554 U.S. at 626 ).

12024–2024
United States v. Greeno green
ca6 · 2012
1 sentence

2024“However, ‘[i]f history proved inconclusive or suggested that the regulated activity was not “categorically unprotected,” -5- No. 1-23-0880 courts proceeded to the second step, whereupon they conducted a means-ends analysis, employing either strict or intermediate scrutiny and weighing the severity of the regulation against the ends the government sought to achieve.’ ” Id. (quoting People v. Brooks, 2023 IL App (1st) 200435, ¶ 67 ). ¶ 17 In Bruen, the Supreme Court adopted a new framework for second amendment claims, holding that “ ‘[w]hen the Second Amendment’s plain text covers an individual

12024–2024

Statutes the citing opinions construe

IL § 720 ILCS 5/24-1 (4) IL § 735 ILCS 5/2-1401 (4)

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.

Where else courts name it

IL 6 (2023–2025) PA 6 (2004–2026) CA 5 (1999–2015) MT 2 (2008–2008)

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.

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