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Friedman v. City of Highland Park

Citations: 68 F. Supp. 3d 895; 2014 U.S. Dist. LEXIS 131363; 2014 WL 4684944Docket: Case No. 1:13-cv-9073

Court: District Court, N.D. Illinois; September 18, 2014; Federal District Court

Narrative Opinion Summary

In this case, the plaintiffs, consisting of a private individual and the Illinois State Rifle Association, challenged a municipal ordinance enacted by the City of Highland Park that bans the possession, sale, or manufacture of certain semiautomatic firearms and large-capacity magazines. The plaintiffs argued that the ordinance infringes upon their Second Amendment rights, asserting that the prohibited firearms are commonly used for lawful purposes, such as self-defense and recreational activities. The court applied a two-part analysis derived from precedent cases to determine whether the ordinance regulated activities protected by the Second Amendment. The ordinance was subjected to a 'not quite strict scrutiny' standard of review, requiring the city to show a substantial relationship between the regulation and its public safety objectives. Highland Park claimed that the banned weapons pose significant public safety risks due to their military features and potential use in mass shootings. Ultimately, the court found that the ordinance did not impose a severe burden on the right to self-defense, as it allowed for the possession of other firearms and magazines with fewer than ten rounds. Therefore, Highland Park's Motion for Summary Judgment was granted, upholding the ordinance, while the plaintiffs' Motion was denied, maintaining the ordinance's validity under constitutional scrutiny.

Legal Issues Addressed

Common Use and Self-Defense

Application: The court evaluated whether the Assault Weapons and LCMs are commonly used for lawful purposes to determine if they are protected by the Second Amendment.

Reasoning: If these weapons are deemed commonly used for lawful purposes, the law is valid only if it aligns with historical practices prohibiting dangerous and unusual weapons.

Public Safety Justification

Application: The city justified the ordinance by emphasizing the public safety risks posed by Assault Weapons and LCMs, particularly their military origins and offensive capabilities.

Reasoning: Highland Park asserts an important interest in public safety, specifically aimed at reducing the threat of mass shootings involving semi-automatic assault weapons.

Second Amendment Scope and Limitations

Application: The court applied a two-part analysis to assess whether the ordinance falls within the protection of the Second Amendment, focusing on whether the banned firearms are commonly used for lawful purposes.

Reasoning: The plaintiffs assert that the banned firearms are commonly utilized for lawful purposes and thus should be considered categorically protected under the Second Amendment.

Standard of Review for Firearm Regulations

Application: The ordinance was reviewed under a 'not quite strict scrutiny' standard, requiring Highland Park to demonstrate a close fit between the ordinance and public safety interests.

Reasoning: Instead, a 'not quite strict scrutiny' standard applies, requiring Highland Park to demonstrate a close fit between the Ordinance and the public interests it serves, justifying the substantial encumbrance on Second Amendment rights.

Summary Judgment Standards

Application: Highland Park's Motion for Summary Judgment was granted because the plaintiffs failed to demonstrate a severe burden on Second Amendment rights.

Reasoning: The Ordinance has been upheld as not infringing on the Second Amendment rights of the plaintiffs. As a result, Highland Park's Motion for Summary Judgment is granted, and the plaintiffs' Motion is denied.