Sensitive Places

This page collects resources for defending laws that restrict carrying guns in “sensitive places” against Second Amendment challenges—including a selection of cases, historical laws, academic articles, and social science. Additional resources will be added over time. Historical laws are also available at the Repository of Historical Gun Laws at Duke Law School. Please get in touch with any questions you might have about these resources, methodology in Second Amendment cases, or any other issues you confront in defending gun safety laws.

Cases

Readers should consider the impact of New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), and United States v. Rahimi, 602 U.S. 680 (2024), with respect to decisions pre-dating those opinions.

Federal Cases

Appellate decisions

1. Antonyuk v. James, 120 F.4th 941 (2d Cir. 2024), cert. denied, No. 24-795 (U.S. Apr. 7, 2025)
   • Issue: challenge to New York’s licensing and sensitive-places laws
   • Procedural posture: appeal from preliminary injunction rulings
   • Holding:
     • Firearms prohibitions upheld at the following locations under Bruen-Rahimi historical analysis:
       • Treatment centers
       • Public parks and zoos
       • Premises licensed for alcohol consumption
       • Theaters
     • Injunction sustained as to firearms prohibition on private property open to the public absent express consent from the owner
     • Several claims were moot or otherwise non-justiciable, including challenges to prohibitions on guns at gatherings expressing the right to protest or to assemble, conference centers, and places of worship
       • Note: Injunction against places of worship restriction upheld in as-applied First Amendment challenge in Antonyuk v. Chiumento, 89 F.4th 271, 352 (2d Cir. 2023)
     • Licensing requirements largely upheld
2. Wolford v. Lopez, 116 F.4th 959 (9th Cir. 2024)
   • Issue: challenge to California and Hawai‘i sensitive-places laws
   • Procedural posture: appeal from preliminary injunction rulings
   • Holding:
     • Firearms prohibitions upheld at the following locations under Bruen-Rahimi historical analysis:
       • Parks, public beaches, athletic areas and facilities, and land controlled by state park and wildlife authorities
       • Playgrounds, youth centers, and immediately adjacent streets or sidewalks
       • Bars and restaurants serving alcohol
       • Casinos, stadiums, amusement parks, zoos, museums, and libraries
       • Parking areas connected solely to sensitive locations
     • Injunction sustained as to prohibitions at the following locations:
       • Places of worship
       • Permitted public gatherings
       • Financial institutions
       • Hospitals and medical facilities
       • Public transit, with no allowance for unloaded and secured firearms
     • As to prohibitions on firearms on private property open to the public without the owner’s express consent:
       • Hawai‘i prohibition (allowed for oral or written owner consent) upheld
       • California prohibition (with specific signage requirement for owner consent) enjoined
3. United States v. Class, 930 F.3d 460 (D.C. Cir. 2019)
   • Issue: challenge to federal law prohibiting firearms on U.S. Capitol grounds, as applied to defendant convicted for possessing firearms in Capitol parking lot
   • Procedural posture: appeal from conviction after guilty plea
   • Holding: federal law upheld under Heller’s sensitive places principle
4. Bonidy v. U.S. Postal Serv., 790 F.3d 1121 (10th Cir. 2015)
   • Issue: challenge to USPS regulation prohibiting firearms on USPS grounds
   • Procedural posture: appeal from summary judgment ruling
   • Holding: regulation upheld as applied to both post office and post office parking lot under Heller’s sensitive places principle (and, as to parking lot, under intermediate scrutiny in the alternative)
5. GeorgiaCarry.Org, Inc. v. Georgia, 687 F.3d 1244 (11th Cir. 2012)
   • Issue: challenge to state law restricting carry in places of worship
   • Procedural posture: appeal from dismissal of complaint
   • Holding: state law upheld because the Second Amendment right does not extend to carrying on private property against the owner’s wishes
6. United States v. Dorosan, 350 F. App’x 874 (5th Cir. 2009) (per curiam) (unpublished)
   • Issue: challenge to USPS regulation prohibiting firearms on USPS grounds, as applied to defendant convicted for possessing firearms in USPS parking lot
   • Procedural posture: appeal from conviction
   • Holding: regulation upheld under the USPS’s authority as property owner and under Heller’s sensitive places principle

District court decisions

1. LaFave v. County of Fairfax, No. 1:23-cv-01605, 2024 WL 3928883 (E.D. Va. Aug. 23, 2024), appeal docketed, No. 24-1886 (4th Cir. Sept. 16, 2024)
   • Issue: challenge to Fairfax County’s prohibition on firearms in county parks and at or adjacent to events that have or should have a county-issued permit
   • Procedural posture: cross-motions for summary judgment
   • Holding: both restrictions upheld under Bruen-Rahimi historical analysis
2. United States v. Metcalf, No. 1:23-cr-00103, 2024 WL 358154 (D. Mont. Jan. 31, 2024), appeal docketed, No. 24-4818 (9th Cir. Aug. 6, 2024)
   • Issue: challenge to federal restriction on firearms within 1000 feet of schools
   • Procedural posture: motion to dismiss indictment
   • Holding: federal prohibition upheld under Bruen’s historical analysis
3. Kipke v. Moore, 695 F. Supp. 3d 638 (D. Md. 2023)
   • Issue: challenge to Maryland’s sensitive-places laws
   • Procedural posture: motion for preliminary injunction
   • Holding:
     • Firearms prohibitions upheld at the following locations under Bruen’s historical analysis:
       • State parks and forests
       • Mass transit facilities
       • School grounds
       • Museums
       • Healthcare facilities
       • Government buildings
       • Stadiums, racetracks, amusement parks, and casinos
     • Injunction granted as to prohibitions at the following locations:
       • Public demonstrations (or in a vehicle within 1000 feet of public demonstrations)
       • Locations selling alcohol for on-site consumption
       • Private property open to the public without the owner’s express consent
   • Neither party appealed the preliminary injunction decision. On subsequent cross-motions for summary judgment, court granted judgment to state for locations listed in (1) and to plaintiffs for those listed in (2). Kipke v. Moore, No. 1:23-cv-01293, 2024 WL 3638025 (D. Md. Aug. 2, 2024), appeal docketed, No. 24-1799 (4th Cir. Aug. 22, 2024)
4. Md. Shall Issue, Inc. v. Montgomery County, 680 F. Supp. 3d 567 (D. Md. 2023), appeal docketed, No. 23-1719 (4th Cir. July 10, 2023)
   • Issue: challenge to Montgomery County’s sensitive-places laws
   • Procedural posture: motion for preliminary injunction
   • Holding: firearms prohibitions upheld at the following locations under Bruen’s historical analysis:
     • • Schools
       • Childcare facilities
       • Places of worship
       • Public parks, recreational facilities, and multipurpose exhibition facilities
       • Public libraries
       • 100-yard buffer zones around places of public assembly and hospitals
5. Goldstein v. Hochul, No. 1:22-cv-08300, 2023 WL 4236164 (S.D.N.Y. June 28, 2023), appeal docketed, No. 23-995 (2d Cir. July 6, 2023)
   • Issue: challenge to state law prohibiting firearms in places of worship
   • Procedural posture: motion for preliminary injunction
   • Holding: prohibition upheld under Bruen’s historical analysis
6. United States v. Allam, 677 F. Supp. 3d 545 (E.D. Tex. 2023), appeal docketed, No. 24-40065 (5th Cir. Feb. 1, 2024)
   • Issue: challenge to federal prohibition on firearms within 1000 feet of schools
   • Procedural posture: motion to dismiss indictment
   • Holding: prohibition upheld under Bruen’s historical analysis
7. Frey v. Nigrelli, 661 F. Supp. 3d 176 (S.D.N.Y. 2023), appeal docketed, No. 23-365 (2d Cir. Mar. 16, 2023) (appeal argued Jan. 30, 2024)
   • Issue: challenge to New York sensitive-places law
   • Procedural posture: motion for preliminary injunction
   • Holding: firearms prohibitions on public transportation and in Times Square area upheld under Bruen’s historical analysis

State Cases

1. DiGiacinto v. Rector & Visitors of George Mason Univ., 704 S.E.2d 365 (Va. 2011)
   • Issue: challenge to state regulation restricting firearms at university buildings and campus events
   • Procedural posture: appeal from dismissal of complaint
   • Holding: regulation upheld under Heller’s sensitive places principle
2. Wade v. Univ. of Michigan, 347 Mich. App. 596 (Mich. Ct. App. 2023), appeal denied, 12 N.W.3d 6 (Mich. 2024), petition for cert. filed, No. 24-773 (U.S. Jan. 16, 2025)
   • Issue: challenge to ordinance restricting firearms on university campus
   • Procedural posture: appeal from summary judgment ruling
   • Holding: ordinance upheld under sensitive places principle from Bruen and Heller
3. Florida Carry, Inc. v. Univ. of Florida, 180 So.3d 137 (Fla. Dist. Ct. App. 2015)
   • Issue: challenge to Florida statute prohibiting firearms on postsecondary school property, including university housing
   • Procedural posture: appeal from summary judgment ruling
   • Holding: statute upheld under Heller’s sensitive places principle

Historical Laws

Schools, Polling Places, Religious Assemblies, and Other Gathering Places

1. Delaware: Del. Const. of 1776, art. XXVIII (“To prevent any violence or force being used at the said elections, no person shall come armed to any of them[.]”) [HeinOnline]
2. New Orleans, Louisiana: Jerome Bayon, General Digest of the Ordinances and Resolutions of the Corporation of New Orleans 371 (1831) (art. 1) (prohibiting “any person to enter into a public ball-room with any cane, stick, sword or any other weapon”  and requiring weapons be checked before entering a ball room) (enacted 1817) [Hathi]
3. New Mexico: 1852 N.M. Laws 67, § 3 (prohibiting “any person to enter said Ball or room adjoining said ball where Liquors are sold, or to remain in said balls or Fandangos with fire arms or other deadly weapons, whether they be shown or concealed upon their persons”) [HeinOnline]
4. Georgia: 1870 Ga. Laws 421, title XVI, no. 285, § 1 (prohibiting carrying “any dirk, bowie-knife, pistol or revolver, or any kind of deadly weapon, to any court of justice, or any election ground or precinct, or any place of public worship, or any other public gathering in this State, except militia muster-grounds”) [HeinOnline]
5. Louisiana: 1870 La. Acts 159-160, no. 100, § 73 (prohibiting carrying “any gun, pistol, bowie knife or other dangerous weapon … on any day of election during the hours the polls are open, or on any day of registration or revision of registration, within a distance of one-half mile of any place of registration or revision of registration”) [HeinOnline]
6. Texas: 1870 Tex. Gen. Laws 63, ch. 46, § 1 (prohibiting carrying any “bowie-knife, dirk or butcher-knife, or fire-arms” at “any church or religious assembly, any school room or other place where persons are assembled for educational, literary or scientific purposes, or into a ball room, social party or other social gathering composed of ladies and gentlemen, or to any election precinct on the day or days of any election, where any portion of the people of this State are collected to vote at any election, or to any other place where people may be assembled to muster or to perform any other public duty, or any other public assembly”) [HeinOnline]
7. Tennessee: 1869-70 Tenn. Pub. Acts 23-24, ch. 22, § 2 (prohibiting “any qualified voter or other person attending any election in this State, or for any person attending any fair, race course, or other public assembly of the people” to carry “any pistol, dirk, bowie-knife, Arkansas tooth-pick, or weapon in form, shape or size, resembling a bowie-knife, or Arkansas tooth-pick, or other deadly or dangerous weapon”) [HeinOnline]
8. Kent County, Maryland: 1874 Md. Laws 366, ch. 250, § 1 (prohibiting carrying “any gun, pistol, dirk, dirk-knife, razor, billy or bludgeon” in Kent County “on the days of election, secretly or otherwise”) [HeinOnline]
9. Missouri: 1875 Mo. Laws 50-51, § 1 (prohibiting carrying “any kind of fire arms, bowie knife, dirk, dagger, slung shot, or other deadly weapon” at “any church or place where people have assembled for religious worship, or into any school room, or into any place where people be assembled for educational, literary or social purposes, or to any election precinct on any election day, or into any court room during the sitting of court, or into any other public assemblage of persons met for other than militia drill, or meetings called under the militia law of this state”) [HeinOnline]
10. Virginia: 1877 Va. Acts 305, ch. 7, § 21 (prohibiting carrying “any gun, pistol, bowie-knife, dagger, or other dangerous weapon, to any place of worship while a meeting for religious purposes is being held at such place”) [HeinOnline]
11. Mississippi: 1878 Miss. Laws 176, ch. 46, § 4 (punishing “any student of any university, college or school, who shall carry concealed” any “bowie knife, pistol, brass knuckles, slung shot or other deadly weapon”) [HeinOnline]
12. New Orleans, Louisiana: Edwin L. Jewell The Laws and Ordinances of the City of New Orleans 1 (1882) (§ 1) (prohibiting carrying “a dangerous weapon, concealed or otherwise, into any theatre, public hall, tavern, picnic ground, place for shows or exhibitions, house or other place of public entertainment or amusement”) (enacted 1879) [Hathi]
13. Calvert County, Maryland: 1886 Md. Laws 315, ch. 189, § 1 (prohibiting carrying “any gun, pistol, dirk, dirk-knife, razor, billy or bludgeon” in Calvert County “on the days of election and primary election, within three hundred yards of the polls, secretly or otherwise”) [HeinOnline]
14. Arizona: 1889 Ariz. Sess. Laws 17, no. 13, § 3 (prohibiting carrying “a pistol or other firearm, dirk, dagger, slung shot, sword cane, spear, brass knuckles, bowie knife, or any other kind of a knife manufactured and sold for the purposes of offense or defense” to “any church or religious assembly, any school room, or other place where persons are assembled for amusement or for educational or scientific purposes, or into any circus, show or public exhibition of any kind, or to a ball room, social party or social gathering, or to any election precinct on the day or days of any election, where any portion of the people of this Territory are collected to vote at any election, or to any other place where people may be assembled to minister or to perform any other public duty, or to any other public assembly”) [HeinOnline]
15. Oklahoma: Will T. Little et al., Statutes of Oklahoma, 1890, at 496 (1890) (art. 47, § 7) (prohibiting carrying any pistol, revolver, bowie knife, dirk, dagger, slung-shot, sword cane, spear, billy, metal knuckles, “or any other offensive or defensive weapon” to “any church or religious assembly, any school room or other place where persons are assembled for public worship, for amusement, or for educational or scientific purposes, or into any circus, show or public exhibition of any kind, or into any ball room, or to any social party or social gathering, or to any election, or to any place where intoxicating liquors are sold, or to any political convention, or to any other public assembly”) [HeinOnline]
16. Mississippi: R. H. Thompson, The Annotated Code of the General Statute Laws of the State of Mississippi 327, § 1030 (1892) (punishing any “student of any university, college, or school, who shall carry, bring, receive, own, or have on the campus, college or school grounds, or within two miles thereof, any weapon the carrying of which concealed is prohibited”) [HeinOnline]
17. Montana: 1903 Mont. Laws 49, § 3 (prohibiting carrying concealed any “pistol or other firearm, dirk, dagger, slung shot, sword cane, knuckles, or bowie knife” at “any church or religious assembly, any school room or other place where persons are assembled for amusement or for educational or scientific purposes, or into any circus, show, or public exhibition of any kind, or into a ball room, social party, or social gathering, or to any election precinct or any place of registration, on the day or days of any election or registration, where any portion of the people of the State are collected to register or vote at any election, or to any other place where people may be assembled to perform any public duty, or at any public assembly”) [HeinOnline]

Parks

Local, state, and federal restrictions on guns in parks are compiled on a separate Parks Restrictions page.

University Rules

Public Universities 

1. University of Georgia: The Minutes of the Senatus Academicus 1799–1842, at 86 (“[N]o student shall be allowed to keep any gun, pistol, Dagger, Dirk sword cane or any other offensive weapon in College or elsewhere[.]”) [University of Georgia]
2. University of Virginia: University of Virginia Board of Visitors Minutes 6-7 (October 4–5, 1824) (“No Student shall, within the precincts of the University, … keep or use weapons or arms of any kind[.]”) [Encyclopedia Virginia]
3. University of North Carolina: Acts of the General Assembly and Ordinances of the Trustees, for the Organization and Government of the University of North Carolina 15 (1838) (“No Student shall keep … fire arms, or gunpowder. He shall not carry, keep, or own at the College, a sword, dirk, sword-cane, or any deadly weapon; nor shall he use fire arms without permission from the President.”) [Google Books]

Private Universities 

1. Harvard College: A Copy of the Laws of Harvard College, 1655, at 10 (1876) (“[N]oe students shall be suffered to have a gun in his or theire chambers or studies, or keepeing for theire use any where else in the town[.]”) [Internet Archive]
2. Yale College: Franklin Bowditch Dexter, Biographical Sketches of the Graduates of Yale College with Annals of the College History May 1745–May 1763, at 8 (v.2 1896) (prohibiting students from “keep[ing] a Gun or Pistol, or Fir[ing] one in the College-Yard or College”) [Google Books]
3. Dickinson College: The Statutes of Dickinson College 22-23 (1830) (prohibiting students from keeping any “gun, firearms or ammunition, sword-dirk, sword-cane, or any deadly weapon whatever”) [Hathi]
4. College of William & Mary: Laws and Regulations of the College of William & Mary 4, 19 (1830) (prohibiting students from “carrying arms privately, shooting or making noise in the night or day in the City,” and from “keep[ing], or [] hav[ing] about their person, any dirk, sword or pistol”) [Google Books]
5. Oakland College: Constitution and Laws of the Institution of Learning Under the Care of the Mississippi Presbytery 10 (1831) (prohibiting “duelling, or aiding or abetting it” and “wearing or carrying a dirk or other deadly weapon”) [Google Books]
6. Waterville College: Laws of Waterville College, Maine 11 (1832) (“No Student shall keep firearms, or any deadly weapon whatever.”) [Google Books]
7. University of Nashville: “University of Nashville,” in American Annals of Education and Instruction for the Year 1837, at 185 (1837) (“No student shall bring, or cause to be brought into College, or, on any occasion, keep in his room … any fire-arms or ammunition of any kind[.]”) [Hathi]
8. Kemper College: The Laws of Kemper College, Near St. Louis, Missouri 9 (1840) (“No Student shall keep arms of any sort, or keep or fire powder on the College premises.”) [Hathi]
9. Illinois College: “Laws of Illinois College, 1850,” in Transactions of the Illinois State Historical Society for the Year 1906, at 245 (1906) (“No student shall carry deadly weapons upon his person, on penalty of admonition, dismission or expulsion[.]”) [Google Books]
10. Albion Female College & Wesleyan Seminary: Eighteenth Annual Catalogue of the Officers and Students of the Albion Female College, and Wesleyan Seminary 32 (1860) (prohibiting “[g]unpowder, firearms, or deadly weapons of any kind on the premises”) [Google Books]

Selected Academic Articles

1. Kellen Heniford & Kari Still, Panic! At the Ballroom: The 1804 New Orleans Ballroom Weapons Ban in a Post-Bruen Context, Buff. L. Rev. (forthcoming 2025) (identifying an 1804 ballroom weapons ban in New Orleans and explaining that the ban illustrates a tradition of prohibiting weapons in places with a high probability of conflict and in places where weapons are incompatible with the function of the location)
2. Darrell A.H. Miller, Alexandra Filindra, Noah Kaplan, & Craig M. Burnett, Technology, Tradition, and “The Terror of the People”, 99 Notre Dame Law Rev. 1373 (2024) (concluding based on empirical studies that the presence of firearms chills attendance at parks, farmers’ markets, protests, and voting locations, such that firearms prohibitions at these places fit within the historical tradition of laws meant to preserve the peace and prevent “the terror of the people”)
3. Kari Still, Kellen Heniford, & Mark Anthony Frassetto, The History and Tradition of Regulating Guns in Parks, 19 Harv. L & Pol’y Rev. 201 (2024) (tracing the history of the American parks movement and of firearms prohibitions in parks and explaining that an unbroken tradition of firearms prohibitions in parks, unchallenged in court, demonstrates that such prohibitions today are constitutional under Bruen)
4. Julia Hesse & Kevin Schascheck II, The Expansive ‘Sensitive Places’ Doctrine: The Limited Right to ‘Keep and Bear’ Arms Outside the Home, 108 Cornell L. Rev. Online 218 (2023) (explaining that history and Second Amendment doctrine support a wide array of sensitive places in which firearms can be prohibited)
5. Joshua Hochman, Note, The Second Amendment On Board: Public and Private Historical Traditions of Firearm Regulation, 133 Yale L.J. 1676 (2024) (explaining that traditions of private firearms restrictions are relevant under the Bruen test, and identifying a tradition of restricting firearms on railways that supports present-day restrictions on public transportation)
6. Joseph Blocher, Jacob D. Charles, & Darrell A.H. Miller, “A Map Is Not the Territory”: The Theory and Future of Sensitive Place Doctrine, 98 N.Y.U. L. Rev. 438 (2023) (concluding that sensitive-places analysis should focus on the underlying reasons that justify restricting firearms in a location, rather than the superficial features of the location)
7. Joseph Blocher & Reva B. Siegel, Guided by History: Protecting the Public Sphere from Weapons Threats Under Bruen, 98 N.Y.U. L. Rev. 1795 (2023) (demonstrating a historical tradition of prohibiting firearms in specific locations in order to safeguard democratic dialogue, governance, and community in the public sphere)
8. Carina Bentata Gryting & Mark Anthony Frassetto, NYSRPA v. Bruen and the Future of the Sensitive Places Doctrine: Rejecting the Ahistorical Government Security Approach, 63 B.C. L. Rev. E. Supp. I.-60 (2022) (demonstrating that the claim that sensitive places are limited to those with government-provided security is contrary to historical tradition, historical case law, and contemporary Second Amendment doctrine as formulated in Heller)
9. Darrell A.H. Miller, Constitutional Conflict and Sensitive Places, 28 Wm. & Mary Bill Rts. J. 459 (2019) (explaining that sensitive places include locations where carrying firearms conflicts with the exercise of other constitutional rights)

Social Science

General

Mass shooters and “gun-free zones” 

1. Louis Klarevas, Rampage Nation: Securing America from Mass Shootings 161 (2016)
   • Of the 111 high-fatality mass shootings that occurred in the U.S. since 1966, only 18 have taken place, in whole or in part, in a gun-free zone or a gun-restricting zone. 84% of all gun massacres occurred in whole or in part where there is no evidence that civilian guns were prohibited, and nearly 90% occurred in whole or in part in locations where civilian guns were allowed or there was armed security or law enforcement.

Schools

Guns on college campuses, feelings of safety, and the academic environment 

1. Jennifer McMahon-Howard et al., Examining the Effects of Passing a Campus Carry Law: Comparing Campus Safety Before and After Georgia’s New Campus Carry Law, 20 J. of Sch. Violence 430 (2021)
   • After Georgia passed a campus carry law, campus members reported a “statistically significant increase in fear of crime on campus, perceptions of [the] campus as unsafe, and lack of confidence in campus police.” Further, “although there was no change in experiencing violent victimization on campus, there was a statistically significant increase in the proportion of campus members who reported experiencing fearful conflicts on campus.”
2. James Shepperd, The anticipated consequences of legalizing guns on college campuses, 5 J. of Threat Assessment and Mgmt. 21 (2018)
   • Survey divided responses by (a) non-gun owners, (b) people who own guns for protection, and (c) people who own guns for non-protection purposes. All three categories reported that “legalizing guns on campus would harm the academic atmosphere and diminish feelings of safety when having heated exchanges or evaluating student outcomes.”

Impulse control, risks of violence, suicide attempts, and risky behavior in college-age students 

1. Daniel W. Webster et al., Firearms on College Campuses: Research Evidence and Policy Implications, Johns Hopkins Bloomberg Sch. of Pub. Health (Oct. 15, 2016)
   • “Risks for violence, suicide attempts, alcohol abuse, and risky behavior are greatly elevated among college-age youth and in the campus environment. The presence of firearms greatly increases the risk of lethal and near-lethal outcomes from these behaviors and in this context.”
2. Scott et al., Young Adulthood as a Transitional Legal Category: Science, Social Change, and Justice Policy, 85 Fordham L. Rev. 641 (2016)
   • “Recently, researchers have found that eighteen- to twenty-one-year-old adults are more like younger adolescents than older adults in their impulsivity under conditions of emotional arousal.” 
3. The Promise of Adolescence: Realizing Opportunity for All Youth, Nat’l Acad. of Sci. 22 (2019)
   • Researchers found that the brain development of adolescence continues into the mid-20s, and that “18-25 year-olds experience a prolonged period of transition to independent adulthood.” 
4. Matthew Miller et al., Guns and Gun Threats at College, 51 J. of Am. College Health 57 (2002)
   • “Students who reported having firearms at college disproportionately reported that they engaged in behaviors that put themselves and others at risk for injury.” 

Use of antidepressants, chronic absenteeism, academic performance, and risk of suicide and accidental deaths in students exposed to school shootings

1. Marika Cabral et al., Trauma at School: The Impacts of Shootings on Students’ Human Capital and Economic Outcomes, Nat’l Bureau of Econ. Research (Dec. 2020)
   • “We find that shooting-exposed students have an increased absence rate and are more likely to be chronically absent and repeat a grade in the two years following the event. We also find adverse long-term impacts on the likelihood of high school graduation, college enrollment and graduation, as well as employment and earnings at ages 24–26.”
2. Phillip Levine and Robin McKnight, Exposure to a School Shooting and Subsequent Well-Being, Nat’l Bureau of Econ. Research (Dec. 2020)
   • “[O]ur findings indicate long-term consequences—including lower test scores, increased absenteeism, and increased subsequent mortality—for those students, and particularly boys, who are exposed to the highest-victimization school shootings.”
3. Maya Rossin-Slater et al., Local exposure to school shootings and youth antidepressant use, 117 PNAS 23484 (Sept. 22, 2020)
   • “[L]ocal exposure to fatal school shootings increases youth antidepressant use by 21.4% in the following 2 years.”

Places of Worship

Religious communities and armed attacks

1. Kimberly Winston, God and Guns, FiveThirtyEight (Nov. 4, 2021) (compiling shootings at houses of worship in the past decade that resulted in more than one fatality) 
2. VOA Special Report: House of Worship Shootings, Voice of America (2020)
   • The percentage of mass shootings motivated by religious hate escalated from 1% during the period 1966-2000, to 9% during the period 2000-2014, and to 18% during the period 2018-February 2020.
3. Federal Bureau of Investigation Crime Data Explorer, Fed. Bureau of Investigation (2020)
   • 15% of hate crimes committed in 2020 were motivated by religious bias. 
4. Mitigating Attacks on Houses of Worship Security Guide, U.S. Dep’t of Homeland Sec. (December 2020) (providing an overview of the types of attacks on houses of worship and specific incidents of armed attacks)
   • An analysis conducted by the Cybersecurity and Infrastructure Security Agency (CISA) looking at targeted violence on places of worship from 2009 to 2019 found that 54% of the attacks were armed assaults, including the use of firearms and other weapons. 
5. Richard R. Johnson, Serious Violence at Places of Worship in the U.S. – Looking at the Numbers, Dolan Consulting Grp. (Sept. 2019)
   • A 2019 study examining the FBI’s National Incident-Based Reporting System (NIBRS) data from 2000 through 2016 found that 1,652 incidents of serious violence occurred at places of worship—including aggravated assaults, shootings, stabbings, and bombings—with 57% of those incidents involving the use of a firearm.

Protests and Demonstrations

Effects of firearms at public protests 

1. Armed Assembly: Guns, Demonstrations, and Political Violence in America, Everytown for Gun Safety & Armed Conflict Locations & Event Data Project (ACLED) (2021)
   • “Roughly one out of every six demonstrations where firearms were present included reports of violent or destructive activity. For demonstrations where no firearms were identified, that figure is one out of 37. While armed demonstrations account for less than 2% of the total number of demonstrations in the US, they account for 10% of all violent or destructive demonstrations. Armed demonstrations turn violent or destructive about 16% of the time, compared to less than 3% of the time for unarmed demonstrations.” 
   • Update: “Over 610 armed demonstrations have been reported around the country since the start of 2020, and they are 6.5 times more likely to turn violent or destructive than demonstrations where no firearms are present.” Fact Sheet: Updated Armed Demonstration Data Released A Year After the 6 January Insurrection Show New Trends, Everytown for Gun Safety & Armed Conflict Locations & Event Data Project (ACLED) (January 5, 2022). 
2. Alexandra Filindra, Americans do not want guns at protests, this research shows, Wash. Post (Nov. 21, 2021)
   • In a nationally representative survey of Black and White Americans, 60% responded that they would be “very unlikely” to attend a protest if guns were present, whereas only 7% said they would be “very likely” to attend such a protest. 
3. Alexandra Filindra, American Identity, Guns, and Political Violence in Black and White: A Report Based on a New National Survey, Univ. of Ill. Chi. (June 14, 2021)
   • In a nationally representative survey of Black and White Americans, 80% responded that “it is inappropriate to bring firearms to a protest.” 
4. Diana Palmer, Fired Up or Shut Down: The Chilling Effect of Open Carry on First Amendment Expression at Public Protests, Ne. Univ. (May 28, 2021)
   1. Study participants were more likely to attend protests and express a belief that protest participation would make a difference in issues that they cared about when no firearms were mentioned. When firearms were mentioned, findings indicated that study participants were unlikely to attend and perceived that their attendance could result in harm or even death. For these participants, the risk of harm outweighed the benefit of making a difference and being heard.

Airports

Increasing presence of firearms at airports 

1. Sherry Towers et al., The Rising Prevalence of Weapons in Unsafe Arming Configurations Discovered in American Airports: the Increasing Practice of Storage and Carry of Firearms with a Round Chambered (2019)
   • Study shows an increase in the number of firearms detected by TSA at airports from 2012 to 2017: “There has been a significant average relative rise of 14% per year in the firearms detected per passenger … There has been a significant average relative annual rise of 4% in the odds of firearms being found loaded.”

Bars

Effects of alcohol consumption on aggression, risky behavior, and firearm violence

1. Charles Branas et al., Alcohol Use and Firearm Violence, 38 Epidemiologic Rev. 32 (2016)
   • 40-year literature review revealed that “over one third of firearm violence decedents had acutely consumed alcohol” prior to their deaths; “that alcohol was significantly associated with firearm use as a suicide means”; and “gun injury after drinking, especially heavy drinking, was statistically significant among self-inflicted firearm injury victims.”
2. Garen Wintemute, Alcohol misuse, firearm violence perpetration, and public police in the United States, 79 Preventative Med. 15 (2015)
   • “Acute and chronic alcohol misuse is positively associated with firearm ownership, risk behaviors involving firearms, and risk for perpetrating both interpersonal and self-directed firearm violence.” Among men, deaths from alcohol-related firearm violence were equivalent to deaths from alcohol-related motor vehicle crashes. 
3. Joseph B. Kuhns et al., The Prevalence of Alcohol-Involved Homicide Offending: A Meta-Analytic Review, 18 Homicide Studs. 251 (2014)
   • “This study meta-analyzes 23 independent studies that included information from 28,265 homicide offenders across nine countries. On average, 48% of homicide offenders were reportedly under the influence of alcohol at the time of the offense and 37% were intoxicated.” These findings suggest that “a substantial proportion of homicides will likely include alcohol as a contributing factor.” 
4. Garen Wintemute, Association between firearm ownership, firearm-related risk and risk reduction behaviours and alcohol-related risk behaviours, 17 Injury Prevention 422 (2011) (finding firearm ownership and specific firearm-related behaviors are associated with alcohol-related risk behaviors)
5. Brad Bushman, Effects of Alcohol on Human Aggression, in Recent Devs. in Alcoholism 227 (1997)
   • Researchers found a correlation between intoxication and increased aggression. Intoxicated individuals experience increased aggression in response to being provoked and experiencing frustrations when compared to sober individuals.

Selected Briefs

Everytown’s amicus briefs in sensitive places cases are available here. 

The following is a selection of recent government briefs in key sensitive places cases, along with links to the dockets. 

1. LaFave v. Fairfax County
   • County’s Brief in Opposition to Motion for Preliminary Injunction (E.D. Va.) (Jan. 5, 2024)
   • District Court docket (E.D. Va., No. 1:23-cv-01605)
2. LaFave v. Fairfax County
   • County’s Brief in Opposition to Motion for Summary Judgment (Fairfax County Circuit Court) (May 6, 2022)
3. Miller v. Smith
   • State’s Motion for Summary Judgment (C.D. Ill.) (Nov. 12, 2021)
   • Court of Appeals docket (7th Cir., No. 22-1482)
4. Wade v. University of Michigan
   • University of Michigan’s Brief (Michigan Supreme Court) (Feb. 8, 2021)
   • Michigan Supreme Court docket and case information (Mich., No. 156150)
5. United States v. Class
   • Government’s Supplemental Brief (D.C. Cir.) (July 13, 2018)
   • Government’s Brief (D.C. Cir.) (Feb. 22, 2016)
   • Court of Appeals docket (D.C. Cir., No. 15-3015)
   • District Court docket (D.D.C., No. 1:13-cr-00253)
6. People v. Chairez
   • State’s Brief (Illinois Supreme Court) (Mar. 17, 2017) 
   • Illinois Supreme Court docket (Ill., No. 121417)
7. GeorgiaCarry.Org, Inc. v. U.S. Army Corps of Eng’rs
   • Government’s Motion for Summary Judgment (N.D. Ga.) (Dec. 23, 2015) 
   • Government’s Brief (11th Cir.) (Dec. 5, 2014) 
   • Court of Appeals docket (11th Cir., No. 14-13739)
   • District Court docket (N.D. Ga., No. 4:14-cv-0139)
8. Morris v. U.S. Army Corps of Eng’rs
   • Government’s Brief (9th Cir.) (Apr. 17, 2015) 
   • Government’s Motion for Summary Judgment (D. Idaho) (May 19, 2014)
   • Court of Appeals docket (9th Cir., No. 14-36049)
   • District Court docket (D. Idaho, No. 3:13-cv-0336)