July 18, 2011 8:33PM # Chicago Still Disrespects Second Amendment By [Ilya Shapiro](https://www.cato.org/people/ilya-shapiro) --- SHARE That’s the upshot of a recent decision by the Seventh Circuit Court of Appeals in the case of *[Ezell v. City of Chicago](http://www.ca7.uscourts.gov/tmp/9O0PHT9O.pdf)*. This was a challenge to the new regulations the city enacted in the wake of *McDonald v. City of Chicago* case, which applied the Second Amendment to the states. In an attempt to circumvent the Supreme Court’s clear holding, Chicago’s ordinance first mandates that would-be gun owners receive training at a firing range but then prohibits firing ranges from operating in the city. The court, in a striking opinion by Judge Diane Sykes (put her on your Supreme Court shortlist for the next Republican administration), tells the city to go back to the drawing board. I won’t go into the details, but the court applied something greater than intermediate (but “not quite strict”) scrutiny and found that Chicago has not presented anything approaching a compelling reason for its restriction. Here’s [an analysis of the opinion](http://joshblackman.com/blog/?p=7500) by Josh Blackman and some [follow-up commentary](http://volokh.com/2011/07/08/ezell/) from Cato associate policy analyst Dave Kopel. Gratifyingly, Judge Sykes cites [the Pandora’s Box article](http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1503583) that Josh and I published early last year in the run-up to the *McDonald* argument (see [footnote 11 on page 31](http://www.ca7.uscourts.gov/tmp/9O0PHT9O.pdf)). It’s quite an honor to appear in the same footnote as Randy Barnett, Steven Calabresi, Brannon Denning, Glenn Harlan Reynolds (the Instapundit), and many other noted scholars — including Akhil Amar, who in the wake of our Obamacare debate and bet may not appreciate it as much. Congratulations to the intrepid Alan Gura (who also litigated *McDonald* and *Heller v. District of Columbia*) and to all the citizens of Chicago! ##### Related Tags [General](https://www.cato.org/general), [Government and Politics](https://www.cato.org/government-politics), [Constitutional Law](https://www.cato.org/constitutional-law), [Robert A. Levy Center for Constitutional Studies](https://www.cato.org/robert-levy-center-constitutional-studies) [![Creative Commons License](/build/cato_2020/images/creative-commons.svg)](http://creativecommons.org/licenses/by-nc-sa/4.0/) This work is licensed under a [Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License](https://creativecommons.org/licenses/by-nc-sa/4.0/).