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This page collects resources for defending laws that restrict carrying guns in “sensitive places” against Second Amendment challenges—including a selection of historical laws, cases, 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.

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[.]”)
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  2. Texas: 1870 Tex. Gen. Laws 63, ch. 46, § 1 (prohibiting weapons 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 . . . or any other public assembly”)
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  3. Louisiana: John Ray, Digest of the Statutes of the State of Louisiana 427 (v.1 1870) (§ 73) (prohibiting carrying dangerous weapons “on any day of election during the hours the polls are opened, or on any day of registration . . . within a distance of one-half mile of any place of registration or revision of registration[.]”)
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  4. 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 arms or dangerous weapons “concealed or otherwise”)
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  5. Georgia: R. H. Clark, The Code of the State of Georgia 818 (1873) (§ 4528) (prohibiting deadly weapons at “any Court of justice, or any election ground, or precinct, or any place of public worship, or any other public gathering in this State”)
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  6. Virginia: 1877 Va. Acts 305, § 21 (prohibiting “carrying any gun, pistol . . . or other dangerous weapon, to any place of worship while a meeting for religious purposes is being held at such place”) 
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  7. 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”)
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  8. Missouri: John A. Hockaday et al., Revised Statutes of the State of Missouri 1879, at 224 (1879) (§ 1274) (prohibiting carrying concealed weapons at “any church or place where people have assembled for religious worship, or into any school room or place where people are 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 any lawful purpose”)
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  9. New Mexico: Chief Justice LeBaron Bradford Prince, The General Laws of New Mexico: Including All the Unrepealed General Laws from the Promulgation of the “Kearney Code” in 1846, to the End of the Legislative Session of 1880, with Supplement, Including the Session of 1882, at 313 (prohibiting drawing or using a deadly weapon in “any ball, dance, or other public gathering of the people, or near where any election authorized by law is being held in any part of the Territory, except it be in the lawful defense of himself, his family, or his property”)
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  10. Calvert County, Maryland: John Prentiss Poe, Maryland Code: Public Local Laws, Adopted by the General Assembly of Maryland, March 14, 1888, at 604 (1888) (§ 71) (prohibiting the carrying of firearms in Calvert County “on the days of election and primary election, within three hundred yards of the polls, secretly or otherwise”)
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  11. Mississippi: R.H. Thompson, The Annotated Code of the General Statute Laws of the State of Mississippi 327 (1892) (§ 1030) (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”) 
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  12. Oklahoma: W. A. McCartney et al., Statutes of Oklahoma, 1893 Being a Compilation of All the Laws Now in Force in the Territory of Oklahoma 504 (1893) (art. 45, § 7) (prohibiting guns at “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 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”)
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  13. Arizona: Revised Statutes of Arizona Territory 1252 (1901) (§ 387) (prohibiting firearms 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, 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”)
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  14. Montana: 1903 Mont. Laws 49, § 3 (prohibiting having or carrying concealed firearms 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”) 
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  1. New York, New York: Fourth Annual Report of the Board of Commissioners of the Central Park 106 (1861) (“All persons are forbidden . . . [t]o carry firearms or to throw stones or other missiles within [Central Park].”)
  2. Philadelphia, Pennsylvania: Acts of Assembly Relating to Fairmount Park 18 (1870) (“No persons shall carry fire-arms, or shoot birds in the Park, or within fifty yards thereof, or throw stones or missiles therein.”) 
  3. St. Louis, Missouri: Michael John Sullivan, The Revised Ordinance of the City of St. Louis, Together with the Constitution of the United States, Constitution of the State of Missouri, the Scheme for the Separation of the Governments of the City and County of St. Louis, the Charter of the City, and a Digest of the Laws Applicable to the City 635 (1881) (§ 3) (“No person shall . . . use or have in his possession ready for use in any street, alley, walk or park of the city of St. Louis” any device that discharges a “fragment, bolt, arrow, pellet, or other missile”) 
  4. Saint Paul, Minnesota: Annual Reports of the City Officers and City Boards of the City of Saint Paul 689 (1889) (“No person shall carry firearms or shoot birds in any Park or within fifty yards thereof, or throw stones or other missiles therein.”)
  5. Williamsport, Pennsylvania: Laws and Ordinances for the Government of the Municipal Corporation of the City of Williamsport, Pennsylvania 141 (1891) (“No person shall carry fire-arms, or shoot in the park, or discharge any fire-works, or throw stones or missiles therein.”)
  6. Wilmington, Delaware: The Charter of the City of Wilmington, Part VII, § 7 (1893) (“No person shall carry fire-arms or shoot birds or other animals within the Park, or throw stones or missiles therein.”)
  7. Detroit, Michigan: 1895 Mich. Local Acts 596, § 44 (prohibiting the carrying or discharging of firearms within the public parks and Grand Boulevard of Detroit without permission of the commissioner)
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  8. Reading, Pennsylvania: A Digest of the Laws and Ordinances for the Government of the Municipal Corporation of the City of Reading, Pennsylvania 240 (1897) (“No person shall carry firearms, or shoot in the common, or within fifty yards thereof, or throw stones or other missiles therein.”)
  9. Boulder, Colorado: Oscar F. Greene, A Revised Ordinances of the City of Boulder 157 (1899) (prohibiting the carrying of firearms into “any of the parks belonging to the City of Boulder”)
  10. Trenton, New Jersey: City of Trenton, New Jersey, Charter and Ordinances 390 (1903) (“No person shall carry firearms or shoot birds in said park or squares, or within fifty yards thereof, or throw stones or other missiles therein.”)
  11. Chicago, Illinois: Amendments to the Revised Municipal Code of Chicago of 1905 and New General Ordinances 40 (1905) (“All persons are forbidden to carry firearms or to throw stones or other missiles within any of the Parks, Public Play Grounds or Bathing Beaches of the City”)
  12. Minnesota: 1905 Minn. Laws 620, ch. 344, § 53 (prohibiting firearms within parks or within “one-half mile of the outer limits” of a park, unless the firearm is unloaded and has been sealed by the park commissioner) 
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  13. Phoenixville, Pennsylvania: A Digest of the Ordinances of Town Council of the Borough of Phoenixville 135 (1906) (“No person shall carry fire-arms or shoot birds or throw stones or other missiles therein [Reeves Park].”)
  14. Oakland, California: General Municipal Ordinances of the City of Oakland, Cal., Addendum at 15 (1909) (“No person shall carry firearms, or shoot birds or throw stones or other miss[i]les within the boundaries of the parks controlled by the Park Commission.”)
  15. Staunton, Virginia: The Code of the City of Staunton, Virginia 115 (1910) (“All persons are forbidden . . . to carry firearms, or to throw stones or other missiles within [the park.]”)
  16. New York City: Ordinances, Rules and Regulations of the Department of Parks of the City of New York 7 (1916) (“No person shall, in any park . . . [f]ire or carry any firearm[.]”)
  17. Birmingham, Alabama: The Code of City of Birmingham, Alabama 662 (1917) (“[N]o person shall carry firearms or throw stones or missiles within any of such public parks[.]”)
  18. Wisconsin: 1917 Wis. Sess. Laws 1243-44, ch. 668, § 3(29.57)(4) (no person shall “have in his possession or under his control therein any gun or rifle, unless the same is unloaded and knocked down or enclosed within its carrying case” while in any “wild life refuge, state park, or state fish hatchery lands”)
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  19. North Carolina: 1921 N.C. Sess. Laws 54, Pub. Laws Extra Sess., ch. 6, § 3 (prohibiting the carrying of a firearm in any park or reservation unless written permission has been obtained from the owner or manager of said park or reservation)
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  20. Federal: 1 Fed. Reg. 668, 674 (June 27, 1936) (prohibiting firearms in national parks and monuments “except upon written permission of the superintendent or custodian”)  
  21. Federal: Individual national parks adopted firearms prohibitions starting in the late nineteenth century. See generallyFirearms Regulations in the National Parks, 1897–1936” (May 13, 2008)

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[.]”) 
  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[.]”) 
  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.”) 

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[.]”) 
  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”)
  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”) 
  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”)
  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”) 
  6. Waterville College: Laws of Waterville College, Maine 11 (1832) (“No Student shall keep firearms, or any deadly weapon whatever.”)
  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[.]”)
  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.”) 
  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[.]”) 
  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”)


Readers should consider the impact of New York State Rifle & Pistol Association v. Bruen, 142 S. Ct. 2111 (2022), with respect to the following decisions. Post-Bruen challenges are working their way through the courts.

Schools and Universities

Federal Cases

  1. United States v. Redwood, 2016 WL 4398082 (N.D. Ill. Aug. 18, 2016) (upholding federal prohibition on possessing a firearm within 1,000 feet of a school under intermediate scrutiny) 
  2. Hall v. Garcia, 2011 WL 995933 (N.D. Cal. Mar. 17, 2011) (upholding California’s Gun-Free School Zone Act prohibiting firearms within 1,000 feet of a school under any level of scrutiny)
  3. United States v. Lewis, 50 V.I. 995 (D.V.I. 2008) (upholding federal prohibition on possessing a firearm within 1,000 feet of a school based on the sensitive places doctrine) 

State Cases

  1. DiGiacinto v. Rector & Visitors of George Mason Univ., 704 S.E.2d 365 (Va. 2011) (rejecting state constitutional challenge to firearms prohibition in university buildings and at campus events because those locations are sensitive places) 
  2. State ex rel. Schmitt v. Mun Choi, 627 S.W.3d 1 (Mo. Ct. App. 2021) (upholding prohibitions on (i) the discharge of firearms, weapons, and explosives and (ii) the possession of weapons and explosives on University of Missouri property under strict scrutiny) 
  3. People v. Green, 121 N.E.3d 911 (Ill. Ct. App. 2018) (striking down prohibition on guns 1,000 feet from a school under heightened intermediate scrutiny) 
  4. Wade v. Univ. of Michigan, 905 N.W.2d 439 (Mich. Ct. App. 2017) (rejecting Second Amendment challenge to firearms prohibition on University of Michigan’s campus because a university is a “school” and is therefore a sensitive place under Heller), appeal granted, 950 N.W.2d 55 (Mich. 2020)
  5. Florida Carry, Inc. v. Univ. of Florida, 180 So.3d 137 (Fla. Dist. Ct. App. 2015) (rejecting constitutional and preemption challenges to Florida statute banning the possession of firearms on postsecondary school property, including university housing, because Heller specifically excluded sensitive places such as schools)
  6. Lyle L. Williams v. Wyoming et al., No. 35077 (Wyo. Dist. Ct. July 2, 2020) (holding that a convention center on a college campus is a sensitive place even when it is being used for private purposes)
  7. Tribble v. State Bd. of Educ., No. 11-0069 (Idaho Dist. Ct. Dec. 7, 2011) (upholding University of Idaho policy prohibiting firearms in University-owned housing under intermediate scrutiny)

Parks and Recreational Areas

Federal Cases

  1. GeorgiaCarry.Org, Inc. v. U.S. Army Corps of Eng’rs, 788 F.3d 1318 (11th Cir. 2015) (affirming district court’s denial of a preliminary injunction against firearms restrictions in U.S. Army Corps recreational areas because plaintiffs had not demonstrated a substantial likelihood of success on the merits) 
  2. Embody v. Ward, 695 F.3d 577 (6th Cir. 2012) (granting officer qualified immunity because “[n]o court has held that the Second Amendment encompasses a right to bear arms within state parks”) 
  3. United States v. Masciandaro, 638 F.3d 458 (4th Cir. 2011) (upholding federal law prohibiting loaded firearms in vehicles in national parks under intermediate scrutiny)
  4. Solomon v. Cook Cnty. Bd. of Comm’rs, 2021 WL 4147167 (N.D. Ill. Sept. 13, 2021) (striking down firearms prohibition in the Forest Preserve District of Cook County under intermediate scrutiny due to lack of evidence in the record that restricting carry by CCL holders would prevent crime in the Forest Preserve) 
  5., Inc. v. U.S. Army Corps of Eng’rs, 212 F. Supp. 3d 1348 (N.D. Ga. 2016) (upholding firearms restrictions in U.S. Army Corps recreational areas under both the sensitive places doctrine and intermediate scrutiny), vacated as moot, 2018 U.S. Dist. LEXIS 171058 (N.D. Ga. July 3, 2018) 
  6. Morris v. U.S. Army Corps of Eng’rs, 60 F. Supp. 3d 1120 (D. Idaho 2014) (striking down firearms prohibition in U.S. Army Corps recreational areas under any level of scrutiny)
  7. United States v. Parker, 919 F. Supp. 2d 1072 (E.D. Cal. 2013) (upholding prohibition on carrying a concealed firearm in a vehicle in a national park under intermediate scrutiny) 
  8. Warden v. Nickels, 697 F. Supp. 2d 1221 (W.D. Wash. 2010) (designating city parks where “children and youth are likely to be present” as sensitive places and upholding firearms prohibitions in those locations under the Washington Constitution) 

State Cases

  1. People v. Chairez, 104 N.E.3d 1158 (Ill. 2018) (striking down firearms prohibition within 1,000 feet of a public park under heightened intermediate scrutiny because the record lacked evidence that the prohibition reduced crime and because the restriction was overly burdensome) 
  2. Bridgeville Rifle & Pistol Club, Ltd. v. Small, 176 A.3d 632 (Del. 2017) (striking down regulations prohibiting firearms in Delaware State Parks and Forests under Art. I, § 20 of the Delaware Constitution) 
  3. People v. Bell, 107 N.E.3d 1047 (Ill. App. Ct. 2018) (upholding firearms prohibition in Illinois public parks under intermediate scrutiny) 
  4. Del. State Sportsmen’s Ass’n v. Garvin, 196 A.3d 1254 (Del. Super. Ct. 2018) (striking down prohibition on open carry at state park campsites and lodges under Art. I, § 20 of the Delaware Constitution) 

Government Buildings and Parking Lots

Federal Cases

  1. United States v. Class, 930 F.3d 460 (D.C. Cir. 2019) (upholding firearms prohibition in parking lot near the Capitol building because the parking lot was “sufficiently integrated with the Capitol” such that it was a sensitive place)
  2. Bonidy v. U.S. Postal Serv., 790 F.3d 1121 (10th Cir. 2015) (upholding firearms prohibition in USPS parking lots because those locations qualified as “government buildings” and were therefore sensitive places) 
  3. United States v. Dorosan, 350 F. App’x 874 (5th Cir. 2009) (per curiam) (upholding firearms prohibition in USPS parking lots under sensitive places exception) 
  4. United States v. Giraitis, 127 F. Supp. 3d 1 (D.R.I. 2015) (upholding law prohibiting possession of a handgun in a federal court facility under any level of scrutiny)

Public Housing

Federal Cases

  1. Doe v. Wilmington Hous. Auth., 880 F. Supp. 2d 513 (D. Del. 2012) (rejecting Second Amendment challenge to firearms prohibition in common areas of public housing under intermediate scrutiny), rev’d in part on other grounds, 568 F. App’x 128 (3d Cir. 2014)  

State Cases 

  1. Doe v. Wilmington Hous. Auth., 88 A.3d 654 (Del. 2014) (striking down firearms prohibition in common areas of public housing under Art. I, § 20 of the Delaware Constitution)
  2. People v. Cunningham, 126 N.E.3d 600 (Ill. App. Ct. 2019) (upholding firearms prohibition for nonresidents in public housing under intermediate scrutiny)


Federal Cases

  1. GeorgiaCarry.Org, Inc. v. Georgia, 687 F.3d 1244 (11th Cir. 2012) (upholding firearms prohibition in places of worship because the Second Amendment does not protect the right to carry on the private property of another)
  2. Nordyke v. King, 563 F.3d 439 (9th Cir. 2009) (upholding firearms prohibition on county property, including open space venues, county parks, and recreational areas, because they are “gathering places where high numbers of people might congregate”), vacated on other grounds, 575 F.3d 890 (9th Cir. 2009)
  3. Miller v. Smith, 2022 WL 782735 (C.D. Ill. Mar. 15, 2022) (upholding handgun prohibition and safe storage requirements at home daycares under the sensitive places doctrine, and upholding safe storage requirement at foster homes under intermediate scrutiny) 

Selected Academic Articles

  1. Darrell Miller, Constitutional Conflict and Sensitive Places, 28 Wm. & Mary Bill Rts. J. 459 (2019) 
  2. Allen Rostron, The Second Amendment on Campus, 14 Geo. J.L. & Pub. Pol’y 245 (2016)
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  3. 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)

Social Science


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.


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.


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.”


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
  2. Miller v. Smith
  3. Wade v. University of Michigan 
  4. United States v. Class
  5. People v. Chairez 
    • State’s Brief (Illinois Supreme Court) (March 17, 2017) 
    • Illinois Supreme Court docket (Ill., No. 121417)
  6. GeorgiaCarry.Org, Inc. v. U.S. Army Corps of Eng’rs 
  7. Morris v. U.S. Army Corps of Eng’rs