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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.
| Case | Followed | Cited |
|---|---|---|
Patrick Atkinson v. Merrick B. Garlandgreen2 sentences2024However, “[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. | 2 | 4 |
People v. Brooksgreen2 sentences2024However, “[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. | 2 | 3 |
New York State Rifle & Pistol Assn., Inc. v. Bruengreen2 sentences2025Indeed, 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 | 1 | 4 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
District of Columbia v. Heller
green
1 sentence2024We 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 ). | 1 | 2024–2024 |
United States v. Greeno
green
1 sentence2024“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 | 1 | 2024–2024 |
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.