Introduction
During
oral arguments in the case of McDonald v.
City of Chicago (2010), Justice Scalia mentions something very interesting
that you should keep in mind while reading this paper. He said “If there’s a
constitutional right, we find what the minimum constitutional right is, and
everything above that is up to the states” (Scalia, 2008 Audio). In fact that is what he did in writing for
the majority in District of Columbia v.
Heller (2008). From 2008 until 2010 the court examined, defined,
incorporated, and applied to the states the protection of an individual’s right
to possess a firearm in their home for private self-defense.
Certainly
one may view these as extraordinary accomplishments, but as with every other
judicial ruling there are vast number critics. Many scholars argue that both
rulings have essentially left judges, legislators, and citizens with more
questions than answers. Moreover, they argue that the court failed to provide
any guidance to as what the proper standard of review to be utilized when
dealing with the new right found in Heller.
I disagree with those claiming the Supreme Court failed to provide guidance to
lower courts regarding the proper standard of review. Rather, the guidance they
claim is lacking can clearly be found in both of the written majority opinions.
District
of Columbia v. Heller (2008)
Until
the 2001 in case of United States v.
Emerson (2001) the Second Amendment was viewed as being a collective right
in connection with militia service. The Emerson
case was the first to hold that the Second Amendment held an individual right
rather than just a collective right. This ruling may very well have sparked the
fire within gun advocates and other around the country and eventually take them
to the Supreme Court in 2008 (Doherty, 2008).
In June 2008 the United States Supreme Court
performed its first thorough and in-depth examination into the meaning of the
Second Amendment. In the case of District
of Columbia v. Heller (2008), Justice Scalia wrote the majority opinion and
he held that the Second Amendment protects an individual’s right to possess a
firearm in their home for self-defense (Scalia, 2008). Washington D.C. arguably
had the most restrictive regulations on handguns in the country. Handgun
possession is banned under District of Columbia law. The law prohibits the
registration of handguns and makes it a crime to carry an unregistered firearm.
Furthermore all lawfully owned firearms must be kept unloaded and dissembled or
bound by a trigger lock unless they are being used for lawful recreational
activities or located in a place of business (Scalia, 2008).
Respondent
Heller was a D.C special police officer and authorized to carry a handgun while
on duty. When Heller applied for a registration certificate that would allow
him to keep a handgun in his home, he was denied. There were 3 provisions of
the Districts handgun ban challenged in this case. However, after reading and
listening to the oral arguments and opinions, it seems clear that the primary
goal of the court was to examine the meaning of the Second Amendment and
determine whether or not there were any rights protected by it. The District
Court dismissed Heller’s complaint. The Court of Appeals for the District of
Columbia Circuit reversed and directed the District Court to enter summary
judgment in favor of the District of Columbia. The Court of Appeals construed
Heller’s complaint as seeking the right to render a firearm operable and carry
it in his home only when necessary for self-defense, and held that the total
ban on handguns violated the individual right to possess firearms under the
Second Amendment. The Supreme Court granted certiorari (Scalia, 2008).
Scalia
delivers an overwhelming 64 page historical analysis of every word in the
amendment. Due to page limit restrictions I will give the main points as
concisely as possible. The right of the people to bear arms pre-existed the
creation of the constitution therefore it seems clear that the right was very
important, possibly even fundamental to the framers. The prefatory clause is
militia related but that does not limit the operative clause (Scalia, 2008).
Historically,
the primary way kings and tyrants would suppress any opposition to their rule
was to disband the peoples militia and also take their firearms. Consequently,
since congress funds our militia and could therefore take away their firearms,
the right of the people to keep and bear arms shall not be infringed. In other
words the right refers to an individual right as in the citizens as opposed to
a collective right. Scalia also stated “This right is not unlimited. Nothing in
our opinion should be taken to cast doubt on longstanding prohibitions on the
possession of firearms by felons, mentally ill, or laws forbidding the carrying
of firearms in sensitive places” (Scalia, 2008).
Justice
Stevens and Justice Breyer each wrote dissenting opinions and they both joined
each other’s opinion. In Justice Stevens dissent the most notable problem he
had with the majority’s opinion was that it threw the court right into the
middle of a debate that has historically been subject to the political process.
Moreover, he argued that the political process is far better at dealing with
these issues, but now the court has stepped in and essentially taken on the
role of a legislature creating a new law (Card, 2009). In his lengthy dissenting opinion, Justice Breyer primarily argues
that the court should develop an interest balancing test. His test would
basically be the equivalent of the level intermediate scrutiny that the court
already uses. However, he suggests that we should give more deference to the
legislature in Second Amendment challenges (Card, 2009).
Controversy
over Scalia’s opinion began the day it was announced. The first claim of their
individual right to possess a handgun after the ruling in Heller, came in the case of United
States v. McCane (2009). In this case McCane was arrested for driving with
a suspended license and after a search of his vehicle turned up a .25 caliber
pistol, he was also charged with being a felon in possession of a firearm. He
was found guilty by the trial court but while awaiting appeal The Supreme Court
issued its opinion in the Heller
case. During his appeal he claimed that he now had a right to possess the
pistol found in his car, but the appeals court upheld his conviction. However,
the court did struggle with defining what prohibitions are considered
“longstanding” and therefore valid as per Heller.
The court eventually moved on stating that since McCane was a multiple felon
the new right would not be enjoyed by him (Mouritsen, 2010).
Otis
McDonald and His Journey to the U.S. Supreme Court
Otis
McDonald was born in Louisiana in 1934. His parents were both sharecroppers
that worked hard to instill a strong work ethic and a sense of pride in their
son. In 1951, during the heart of the Great Migration, in which millions of
African American’s moved from Southern states to Northern states, Otis asked
his mother for $18 so that he could make his way North. Eventually he settled
down in Chicago where he went to work as a janitor for the University of
Chicago where he retired as a father of 8 in 1997(Mastony, 2010)
In
2008, after his successful argument in the case of District of Columbia v. Heller (2008), attorney Alan Gura set his
sights on Chicago and its strict handgun ban that closely resembled the ban
Washington D.C. formally had. Gura established connections with 12 Chicago
residents and proceeded to interview them over the phone and email. He finally
narrowed the field down to 4 people in which he would represent in a future
lawsuit. The 4 were Adam Orlov who was a partner in a trading firm. David
Lawson, a white software engineer. Colleen Lawson, the wife of David Lawson,
she was a hypnotherapist. Lastly, there was Otis McDonald, a black janitor (Mastony,
2010).
McDonald’s
concern over Chicago’s push for a widespread handgun ban led him to begin
attending pro-gun rallies in 2005. As he became more involved in the rallies,
he caught the attention of Valinda Rowe. Rowe was one of the leading activists,
and upon hearing that Gura was looking for potential plaintiffs to challenge
the city’s ban, she gave Gura McDonald’s phone number. Eventually Gura flew to
Chicago to meet with the 4 people he selected and decided that McDonald would
be the lead plaintiff, thus creating McDonald
v. City of Chicago (2010). At one point during their meeting McDonald said
“Why would you name it after me? Is it just because I’m the only black” (Mastony,
2010)? Although he was only joking when he said that, it would end up playing
an interesting role in Gura’s development of his argument.
McDonald
had firsthand experience when it came to being a victim of the widespread crime
wave that took place in his neighborhood. His house was burglarized three times
in 1980’s and 1990’s. More recently a couple of teenagers had surrounded his
car while pointing a gun in his face and making death threats. That was the
last straw for McDonald. Soon after in 2008 he went to the Chicago Police
Department where he applied for a .22- caliber pistol and thus setting the lawsuit
into motion (Mastony, 2010).
McDonald
v. City of Chicago (2010)
This
litigation began when Chicago residents brought suit challenging local
ordinances that essentially banned all handgun possession by anyone in the
city. Specifically, the petitioner Otis McDonald sought a permit to purchase a
handgun to be kept in his home for safety, but his application was denied. Soon
thereafter McDonald and 3 other petitioners filed suit against Chicago’s
handgun ban. The district court
dismissed the suits and the U.S. Court of Appeals for the Seventh Circuit
affirmed (Mastony, 2010). Upon the granting of certiorari by the U.S. Supreme
Court, the McDonald case was joined by a similar case involving the NRA in
which Attorney Paul Clement represented. The Supreme Court combined the two and
allowed 15 minutes for both McDonald and the NRA during oral arguments. James
A. Feldman was hired to represent the City of Chicago.
The
main questioned presented in this case is whether or not the right identified
in the Heller should be incorporated
under the Fourteenth Amendment thus making it applicable to the states.
Moreover, it would also provide protection from infringement by state actions.
Shockingly, Mr. Gura on behalf of the petitioners argued that the right found in
Heller is one of the privileges or
immunities of national citizenship and therefore should be incorporated via the
Privileges or Immunities Clause of the Fourteenth Amendment. On the other hand,
Mr. Clement on behalf of the NRA argued that the right should be classified as
a fundamental right and incorporated via the Due Process Clause of the
Fourteenth Amendment. Mr. Feldman, representing Chicago, maintained that the
city’s handgun ban was necessary to save human lives. For years Chicago claimed
that the total ban of handguns within city limits had saved hundreds of live.
Furthermore, Chicago claimed that its banning of handguns was a proper exercise
of its police powers to protect its citizens.
In
a 5-4 decision the Supreme Court reversed the Seventh Circuit’s ruling. Justice
Alito wrote the majority opinion holding that “Rights found to be fundamental to the Nation's scheme of ordered
liberty" or that are "deeply rooted in this Nation's history and
tradition" are appropriately applied to the states through the Fourteenth
Amendment. The Court restated that the right found in Heller was deemed to be "fundamental" and "deeply
rooted” (Alito, 2010). Moreover, the
court rejected the argument made by McDonald and instead incorporated the
Second Amendment under the Due Process Clause.
Justice Stevens wrote a dissenting opinion and Justice
Breyer wrote a separate dissenting opinion in which justices Ginsburg and
Sotomayor joined. The first of four points Justice Breyer
argues is that the fear of the federal government taking away the arms of the
militia was the reason the Second Amendment was codified. He then mentions that
there is no consensus in America that the possession of a firearm for
self-defense is a fundamental right. Thirdly, he looks at the other rights that
have been incorporated and argues that unlike those rights, the right to
possess a firearm for self-defense does not advance any constitutional
objective (Oyez, 2009).
Specifically,
he states the constitutions objective to protect the rights of a minority
against acts of a majority, such as the First, Fourth, and Eighth Amendments
effectively do. Lastly he argues that there is a substantial reason to believe
that the incorporation of this right will drastically interfere with the
constitutional objectives of courts and legislatures and the states to the
federal government. Essentially he claimed that states have already established
extensive laws and regulations regarding firearms and by incorporating this new
right, all such laws and regulations are now subject to constitutional
challenges. Furthermore, he asks how federally appointed judges compared to
elected representatives are better suited to answer all of the questions that
are sure to arise (Oyez, 2009).
Aftermath
& Implications of Heller & McDonald
The
first question that came to my mind after studying these cases is whether or
not the rate of crimes involving handguns increased or decreased in D.C. and
Chicago after their handgun bans were struck down. I researched this very
question extensively and only found one article with any sort of answer which I
find as shocking as the results I found. According to John Lott, who hold a
Ph.D. in economics with focus on research in law and economics the crime rates
for Washington D.C. and Chicago after their handgun bans were struck down are
as follows (Lott, 2011)
Crime
rates for Washington D.C.
·
Homicides from 2008-2012 dropped -35%
·
Robbery with a gun dropped -10.3%
·
Assault with a gun dropped -24.1%
·
Total violent crime dropped -9.5%
Crime
rates for the City of Chicago from Jan-Jun 2010 and Jan-Jun 2011:
·
Murder dropped -14%
·
Robbery dropped -3.8%
·
Aggravated assault and aggravated
battery combined dropped -27.3%
·
Total violent crime dropped -8.8% (Lott, 2011)
Although
the national crime rates have been dropping for years, D.C. and Chicago’s rates
have surpassed it. Accordingly the notion of more guns less crime may actually
have some substance to it.
Soon
after the McDonald opinion was read
there was a flood of challenges against federal, state, and local gun laws and
regulations. One example is the case of United
States v. Skoien (2010). The challengers brought suit claiming that the
federal law barring gun ownership by people convicted of domestic violence
charges was a violation of their Second Amendment right to bear arms. The 3
judge panel of the 7th Circuit Court of Appeals held the law to in
fact be unconstitutional in violation of his Second Amendment right to bear arms.
However, on appeal to the full 7th Circuit Court of Appeals the
court upheld the law. In its opinion the court stated that it applied
intermediate scrutiny when reviewing the law (Vernick, 2011).
What
makes this case even more interesting is the fact that the court relied heavily
on research regarding a few topics: the relationship between domestic violence
and firearms, recidivism among domestic abusers, and the risk of guns in their
homes. (Vernick, 2011) The majority in the McDonald
case held that when addressing constitutional issues, the court does not base
its ruling on statistics. However, in his dissenting opinion Justice Breyer
argued the exact opposite in regards to Second Amendment issues.
He
states “This is a highly statistical matter. Without incorporation it’s decided
by legislatures, with incorporation it’s decided by judges” (Oyez, 2009). A few moments later during oral
arguments Justice Breyer goes on to say “There is always a big area where its
free speech versus a whole lot of things, but not often is it free speech
versus life. When it’s free speech
versus life, we very often decide in favor of life. Here every case will be one
side guns on the other side life. Statistics, balancing life versus guns” (Oyez,
2009). Apparently the 7th Circuit Court of Appeals agreed with Justice Breyer’s
argument that statistics must be considered.
Another
case directly stemming from the Heller
and McDonald rulings is Britt v. State (2009) in which North
Carolina became the first state in the country to hold that a law criminalizing
an ex-felon from possessing a firearm to be a violation of their Second
Amendment right and therefore is unconstitutional. In 1979 Britt was convicted
of felony possession with intent to sell and deliver a controlled substance. He
completed his sentence and was released in 1982 and his civil rights were
restored in 1987. The law in 1987
allowed for Britt to purchase certain firearms, and he did purchase some
firearms such as sporting rifles and shotguns. However, in 2004, North Carolina
passed a law making it illegal for anyone who has been convicted of a felony to
possess any sort of firearm (Bone, 2010).
Britt
voluntarily turned in his firearms and then filed a suit alleging that the new
law violated his right to bear arms. Moreover, Britt had not been charged with
any crime in the 30 years since his first and only felony conviction. The trial
court held the law was rationally related to a legitimate state interest and
therefore valid and the court of Appeals affirmed. However, on appeal to the
North Carolina Supreme Court, the court found the law unconstitutional as it
applied to Britt because the state could not imply that Britt possessed a significant
threat to public safety (Bone, 2010).
After
the Britt case, the North Carolina
Court of Appeals developed and implemented a 5 factor test in order to
determine whether the statute is a “reasonable regulation which is fairly
related to the preservation of public peace and safety” (Bone, 2010).
1.
The type of felony convictions, particularly
whether they involved violence or the threat of violence.
2.
The remoteness in time of the felony
convictions
3.
The felon’s history of law-abiding
conduct since the crime
4.
The felons history of responsible lawful
firearm possession during a time period when possession of firearms was not
prohibited
5.
The felon’s assiduous and proactive
compliance with the 2004 amendment
Indiana
is not exempt from the implications of the Heller
and McDonald cases. In 2011 Indiana
enacted a law that prohibits employers from prohibiting their employees from
keeping a lawfully owned firearm unloaded and locked in their vehicle while at
work. Also in 2011 Indiana passed a law that prohibits local governments in from
enacting any type of firearm regulation that is not mentioned in the Indiana
Code. In other words Indiana’s General Assembly wanted to establish uniform
firearm laws throughout all parts of the state. Therefore, unless it’s already
in the Indiana Code, a city may not pass a more restrictive firearm regulation
(Bischoff, 2010).
Misconceptions
of the Heller and McDonald rulings
In
conducting research for this paper I have easily read over 500 printed pages on
this subject matter. From law reviews and legal journals to scholarly peer
reviewed articles and Supreme Court audio recordings, not to mention an unknown
amount of online articles. As a result I would like to think that I have
developed at least a very basic understanding of these two cases and their
implications to our society. Most of the articles I read were very critical of
the Supreme Court’s rulings in both cases.
There are numerous issues scholars have found in the court’s rulings;
but the most common issue mentioned by nearly every article I read was that the
court failed to offer any guidance to lower courts in regards to what the
proper standard of review should be for this new right.
Many scholars blast the court because in its
failing to provide a clear standard of review the court has created a great
divergence among state and federal courts. Specifically, as to the proper way
they should address the flood of Second Amendment violation claims currently
being made. As Justice Breyer argues in his dissent, which is now joined with
many in the academic community, nearly all state and federal regulations and
prohibition’s regarding firearms are now subject to constitutional challenge.
Furthermore, empirical evidence must be considered when comparing a state’s
interests vs. an individual’s right to possess a handgun; and that the
political process in state legislatures and in Congress are better equipped to
answer such questions.
The
argument I kept coming across goes on to ask what level of scrutiny should be
applied. For example should rational basis be enough? Should intermediate
scrutiny be used in this case? What about strict scrutiny in this circumstance?
As I progressed in my research my pro-gun stance remained intact but my
objective analysis of the issues gave way to Justice Beyer’s argument. It just
made sense to me that a single judge, a panel of judges, and even the Supreme
Court is not where we should be looking for answers to all the questions that
are now presented. Rather, I agree with Justice Breyer that legislatures have
the tools to conduct research, analyze their findings, and pass appropriate
legislation in accordance with such findings.
Just
when I thought I had settled on my theme and format of this paper it hit me.
The U.S. Supreme Court did give proper guidance to lower courts. In fact the
guidance and the answers to all of the questions about who can possess
handguns, where, and what type were answered by Justice Scalia’s opinion in Heller and then passed on to the states
in McDonald. What sparked this
revolution in my head was an article claiming that originalism is dying and
Justice Scalia’s 64 page opinion is proof that his approach to constitutional
interpretation is nearly obsolete. The author claims that Justice Scalia’s
opinion is so lengthy because he is desperately trying to prove that
originalism and textualism together are the best ways to interpret the
constitution.
After
reading the article I read the opinions in both cases and I also listened to
the oral arguments and opinions for the 50th time. During oral
arguments in the McDonald case
Justice Scalia says “If there’s a constitutional right, we find what the
minimum constitutional right is, and everything above that is up to the states”
(Scalia, 2008 Audio). Having that
been said, if you read the majority’s opinion in Heller, Justice Scalia is doing exactly what he said above.
We
must remember that the Heller case
was the courts first full examination of the Second Amendment. Therefore,
Justice Scalia thoroughly looked at all parts of the Amendment and found that
the minimum right protected is an individual’s right to possess a handgun in
their home for lawful purposes. Moreover, the court held that the right is not
unlimited and that longstanding regulations regarding who may purchase or carry
a handgun, restrictions on where a person may possess a handgun are
presumptively valid so long as a law, regulation, or prohibition does not
totally ban all handguns and does not restrict law abiding citizens from
purchasing one and keeping it in their home for lawful purposes.
The
court in the McDonald case applied
the right identified by Justice Scalia’s opinion in its entirety to the states.
In other words, all law, regulations, and prohibitions that were in place prior
to the Heller ruling are still
lawful; so long as they do not totally ban all handguns and prohibit lawful
citizens from possessing a handgun in their home for lawful purposes.
Therefore, all the articles by highly respected scholars and lawyers that I
read criticizing the court for not allowing state legislatures to regulate
handgun possession; and for not providing the courts with any guidance to
answer questions of who, where, what type and handgun, and what standard of
scrutiny should be used, are wrong in their criticism. States may do everything
they did prior to Heller and McDonald except for what I mentioned
above and that really is not much. It seems to me that most scholars view these
two cases as creating a narrow right with no definition, but in reality the
court simply found the minimum constitutional right and clearly stated that
everything above that is up to the states.
What
I find most troubling about is that people are looking to the U.S. Constitution
to solve all their problems and they expect the constitution to provide answers
to every question they have. In doing so they are changing the constitution
into something it was never meant to be. They are essentially changing the
constitution into a document that is expected to keep up with our current
society and reflect our societal views. That type of constitution is not what
our founding fathers sought to create. Rather, keeping up with society and
reflecting our current society’s views is precisely the job of Congress and our
state legislatures.
In
nearly every article I read that attacking the Supreme Court, I rarely found
any mention about their state constitutions. After all most state constitutions
provide greater protections of citizens’ rights than does the U.S.
Constitution. Therefore, if they people would rather look to a constitution to
reflect their current values, they should first look at their own state
constitution. In regards to an individual’s right to bear arms, state
constitution’s often times provide a significantly greater level of protection
compared to the U.S. Constitution.
Indiana’s
Constitution provides “The people shall have the right to bear arms, for the
defense of themselves and the State.”
Maine’s Constitution says “Every citizen has a right to keep and bear
arms and this right shall never be questioned.” Alabama’s Constitution says
“That every citizen has a right to bear arms in defense of himself and the
state.” Delaware’s Constitution provides “A person has the right to keep and
bear arms for the defense of self, family, home and State, and for hunting and
recreational use.” Louisiana’s Constitution states “The right of each citizen
to keep and bear arms shall not be abridged, but this provision shall not
prevent the passage of laws to prohibit the carrying of weapons concealed on
the person” (Volokh, 2006). Only six
states fail to enumerate a right to keep and bear arms, California, Iowa,
Maryland, Minnesota, New Jersey, and New York (Volokh, 2006).
Conclusion
The
U.S. Supreme Court’s rulings in Heller
and McDonald can easily been labeled
as historical landmark decision’s, but it appears that there are a lot of
citizens and scholars that view the decisions as being much more significant
than they really are. The court’s decision in Heller was its first examination of the Second Amendment and it
effectively did what it was supposed to do. That being that it identified the
minimum constitutionally protected right and left everything above that right
up to the states via the McDonald
case. If we wish to preserve our constitution that has lasted hundreds of
years, we must not look to it for answers to every single issue that develops
in our society. Furthermore, judges must be cautious when taking an approach to
constitutional interpretation that weighs a right or a statue against what they
think may happen.
For
example instead of looking at the plain text and what the Second Amendment
originally meant to the people who drafted it,
Justice Breyer took on the role of a sociologist and relied on
statistics as the bases for his opinion. Consequently, as shown above, the
handgun ban may have very well increased crime rates in D.C. and Chicago, or at
the very least significantly slowed their drop in crime rates. Certainly all
methods of constitutional interpretation should be made available depending on
the case, but when dealing with an issue that is spelled out in the
constitution the easiest and most appropriate method is originalism and
textualism. Lastly, state governments, state courts, and federal courts need to
stop reading into Heller and McDonald for anything more than what
they say. Rather, they need to follow the North Carolina Court of Appeals lead
and develop whatever tests they deem appropriate.
References
Alito,
S. (2010). Opinion of McDonald v. City of Chicago (United States of
America, United States Supreme Court). Washington D.C.: United States Reports.
Bischoff.
(2010, January 26). House Bill No. 1065 (The United States of America,
Indiana General Assembly, House of Representatives).
Bone,
D. (2010). The Heller promise versus the Heller reality: Will statutes
prohibiting the possession of firearms by ex-felons be upheld after Britt v. State? Journal of Criminal Law & Criminology, 100(4), 1633-1658.
Card,
R. L. (2009). An opinion without standards: The Supreme Court’s refusal to
adopt a standard of constitutional review in District of Columbia v. Heller will likely cause headaches for
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S. C. (2010). United States v. McCane:
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