University of Michigan campus carry guns
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Nonetheless, it seems apparent that large, modern university campuses differ from their historical antecedents. Many are involved in urban planning with mixed-use projects that include shops and nonstudent residences.

The University of Michigan itself occupies nearly one-tenth of Ann Arbor. Many areas on campus, such as roadways, open areas, shopping districts, or restaurants, might not fit the “sensitive place” model suggested by Heller—they may instead be more historically analogous to other locations that did not have gun restrictions. And because the campus is so entwined with the surrounding community, the ban might also burden carrying rights on locations outside campus, as many individuals will regularly go from campus to off-campus environments, even in a single trip; because they cannot bring a gun on campus, they will not feasibly be able to bring the gun to the off-campus locations either.

{See, e.g., Note, Rethinking the Nevada Campus Protection Act: Future Challenges & Reaching a Legislative Compromise, 15 Nev L J 389, 421-422 (2014) (“Current laws and university policies that prohibit any degree of campus carry leave [carrying a concealed firearm] permit holders defenseless anywhere between college campuses and home. The professor that stops for groceries after work; the student that stops for gas across the street from campus; these are the real and unfortunately less documented dangers of ‘no permission to campus carry’ states.”); id. at 425 (“The line that separates some universities from public property is fuzzy, and attempting to classify universities as a ‘sensitive place’ poses a significant problem. Universities are typically intermingled with other services and public property.”); Guns on Campus, 38 J C & U L at 675 (“Additionally, some colleges and universities do not have the clearly defined perimeters that high schools, middle schools, and elementary schools usually have. Some colleges and universities span across city-scapes and mix with metropolitan areas. The physical layout of some colleges and universities can easily create confusion for individuals trying to determine if they are on campus or off campus at any given point. For example, public roads often run through college campuses. Could a public road be considered a sensitive school area subject to a reasonable regulation, or would the street merely be part of the public landscape where the same regulation would be unreasonable?”).}

I believe that these considerations are necessary in the present case when applying the governing framework from Bruen. Because they require careful analysis of historical materials, I agree that a remand is appropriate.

— Eugene Volokh in Second Amendment Challenge to University of Michigan Gun Ban

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    • Knucklehead authors who pay omage to concealed carry permits as a way to gain ground do nothing but crown the state king.

      Instead of the focus being on an individual’s right to keep and bear arms the king says who gets issued a license to survive a criminal attack. When it comes between bowing down to please the king and you and yours being kidnapped, beaten, murdered, etc. the king can take his concealed carry permits and go pound sand.

  1. Somebody convince me that No Guns signs, and similar restrictions, have any effect whatsoever on somebody intent on mayhem and murder.

    • The effect has been demonstrated numerous times. The person intent on mayhem and murder is effected by the knowledge that they can commit their offense without fear of being stopped by an armed defender.

      Gun Free Zones = Defenseless targets.

      • LOL. Yeah, that’s what I thought. 🙂 As a side note, I share a property line with a K-12 school. I live on 30acres of forest, and I shoot and hunt on my property for the last 20+years. Never had a single complaint in all that time, and not one of my guns has ever gone on a rampage thru the school.

        • If you have a k-12 school probably rural. Country people have more common sense than city people. Everyone probably knows Gunney Gene too.

        • Somewhat similar. Grandfather owned land adjacent to the Jr/Sr high school. Friends of the family owned more land, also adjacent to the school. We hunted and target practiced all the time, often times carrying firearms across school property. Never heard any kind of complaint.

          Of course, I’m an old man today, so that was a lifetime ago.

      • Most mass attack perps are not deterred by long prison sentences, they know that prison life is better than what they have out on the street. It’s an easy out for them. Being killed is NOT a part of most plans, so target selection is important. Even Cruz thinks he will be released someday.

        • I agree that prison sentences aren’t a deterrent for most of them. However, I believe that most of these scum don’t plan on surviving. They’re committing suicide (either by their own hand or by responding cop) and taking as many people with them as they can. Not having armed resistance let’s them up their body count. Not mentioning their names denies them the infamy they crave as a coda to their worthless lives.

        • THAT is bull leavings. Most mass attack perps have no idea what prison is like and do it for many other reasons. They don’t think about the consequences at all, they usually are not adult in minds, they are immature and very frustrated with life as an adolescent.
          Yes, most(if not all) were damaged as children mentally and were never able to have their moment in the sun. And I agree with Anymouse.
          If the gangbangers got caught and truly sentenced, what was said about the perps life not being so different in the hood or jail. These JDs have an idea what jail is because they are familiar with Juvenile Hall and the foster care system. The shooters with the highest body counts usually don’t try to get away, have no plan to, while the hood rats do the deed and then ghost.

    • Never been one substantiated verified study that shows they have any effect on stopping criminals with guns. There are politicians and articles and puff pieces claiming that such and such a study does this or that to show they are effective with stopping criminals with guns, but its not true and is just trying to mostly anecdotally shore up yet another failed policy of ‘lets look like we are doing something see we can get funds for gun-control that doesn’t work’.

      My favorite part of such bogus study’s is their ‘data set group’. One study ‘data set group’ surveyed criminals that had been caught committing crime in a ‘gun free zone’ with a knife and asked them why they didn’t use a gun to which the criminals replied they didn’t have a gun to use – they went in the win column supporting ‘gun free zone’ signs because it deterred them from using a gun. These guys didn’t have guns they could have used to begin with which is why they used a knife but here they are as having been ‘deterred from gun use’ by a ‘gun free zone sign’. These are the types of tricks the anti-gun industry wants to use and sadly there are idiots who will believe it.

      • As you note, stablishing the “dataset group” is the core of any study/statistical analysis. It is one reason I never take political polling into consideration, no matter what.

    • Their power is less that of restraining orders and there is no shortage of corpses that once held restraining orders against their killers.

  2. the univ. clowns don’t want their chimps shot-up as they go about assaulting, car-jacking, raping, etc.

  3. Translation: “I feel obliged to display my lawyerly sophistication by finding nuance where there is none. I will pretend the long list of arguments against the law create a complex situation, while pointedly ignoring how simple it is to weigh those arguments against the complete absence of evidence – contemporary or historical – for either its effectiveness or Bruen constitutionality.”

  4. “For example, public roads often run through college campuses. Could a public road be considered a sensitive school area subject to a reasonable regulation, or would the street merely be part of the public landscape where the same regulation would be unreasonable?”).”

    This is where things will get *interesting* in the years ahead.

    ‘Interesting’ as in infringement, that is. The ‘GVR’ is going to get quite a work-out, but I do get a massive rush out of seeing the courts self-edit themselves by issuing rulings that go completely against the way they really want to rule…

    • Ohio has dealt with the for years.

      The road’s public, the sidewalk and the curb are public. Off campus housing surrounded by university property is fine as long as you don’t transit university property with a firearm. So you can’t keep your burner on you and walk next door to your buddy’s place but you can carry a gun to and from your abode.

      Where this gets tricky is if an “island” is created by a set of university owned roads that encircle public roads. (Also makes for a fun time when the snowplows fight over who plows what and were. My answer was always “Me, your mom/wife/girlfriend/daughter, wherever I want” which got a laugh from the people who drove the plows.)

      I’m not aware of any university ever attempting to enforce the law on the “barriers” to an “island” because, how would they know as you crossed an intersection? Further, generally it wasn’t worth their time because if you bothered with a map you could eventually find a path you “could have taken” and they didn’t want that bullshit since they pretty much knew they’d lose and probably get sued over it.

      “Well, officer, I knew the law so I got out and parked on the public road and used the public sidewalk to go to private property A, jumped the fence to private property B, then walked down this public sidewalk here, turned left and walked down the public sidewalk to my place, then I entered the private property which I am renting. Trespassing? No, sir, I would never. I did this while house-parties were in full swing and, obviously, before I’d had a single sip because guns and alcohol aren’t Saf-T Squirrel approved. Then I returned to my car and retrieved it, parking in front of my house.

      …That’s just before I got shitfaced and put it in your daughter’s ass as she did lines off some sophomore chick’s stomach and went down on her for like half an hour.

      Hand to God, officer, that’s what happened and how I legally transported a firearm to this location.”

  5. My how those anti-gun radicals just love their “gun free zones (actually TARGET RICH ENVIRONMENTS)”

    • Laws do matter. If you want to stay out of the gulag you need to not get caught.

      Can you imagine being in prison when the apocalypse kicks off?

      • It’s truly cute that you believe that.

        If they want to put you in prison, they’ll just make shit up. Or, they’ll just kill you in a one-way gunfight with some “heros” and put some shit on your computer to *find* later on, proving that you deserved to be shot 27 times while *battling the cops* by lying asleep in your bed.

        Damn shame the dogs were wild curs too. “Pitts” I hear, a vicious breed worthy of extermination, just like those that own them, amirite?

        • I’ve been on the two way range. If anybody thinks its going to be one way at my place they are in for a real awakening. I’m old. Dying a day at a time does not appeal.

        • Would that i could say that’s bullshit. Having lived it, I know damned well the contrary.

          The only fortunate side legally in my case, is the made up garbage was piddly shit. They sure well had no problem coming in the middle of the night in the meantime while we slept to kill me, and I have it on video. 6 videos to be more specific.

          If I’d been on my back porch smoking instead of dead asleep, I wouldn’t be here at all given the way that Deputy was jumping out of his skin as he rounded the porch corner drawn down.

          Stalker shitbag tried to have me S.W.A.T.-ted, and they had no issue at all with accommodating his request. Reason 4,532 I had no problem popping that dirtbag when I got the legal opportunity.

          Same cameras cleared me of any wrongdoing. In the end, not only was quashed with prejudice, also returning my gunm, and even the empty hull as well. I win, gimme my mo-nay. Except it took almost $20k and 2.5 years to get my rights back.

          Buuuuut you complied… No the fuck I didn’t. I wasn’t disarmed for a single solitary second once I was bailed out. If they’d breached, there was hell waiting with Lvl IV behind door #2.

          I am still super fucking pissed at what I saw on that camera footage the next day. And, I’m sure you won’t be surprised to learn the AG won’t move on anything despite the evidence…

          Fuck ’em.

        • Generally speaking, I’ve considered myself to be pretty pro-police for most of my life. Even when they decided to fuck with me. Cost of doing business and whatnot. They’re not perfect, jaded from dealing with scumbags all the time, mistakes happen, yadda, yadda.

          I’ve done my level best to judge each case individually. Credit where it’s due and criticism where that’s due etc.

          However, the past two years have pretty well convinced me that most (not all!) cops in the US, and the West in general, are shitbags who will do whatever they’re told and if you get dead they don’t really care. Doing the right thing? Maybe. Depends on a host of factors but mostly they only seem to do that if it’s the path of least resistance. Rights? Well, let’s not even have that conversation.

          These days when I hear someone say “Back the Blue!” I think “Yeah, back them right into a literal corner and then machine gun the lot of them. Survivors get a coup de grace from a bayonet. Take that, film it in 8K and make a training video for the Academy where new recruits watch the video on a loop the way Alex watched videos in A Clockwork Orange.

          I guess it’s not hard for me to do that. I’ve long understood that cops are agents of the State and that the State is not your friend. It thinks of you the way a farmer thinks of cows or sheep. You’re a beast to be milked for “productive value” until it’s time to get rid of you. The cops have just gone ahead and shown that they know this and don’t care. Interesting that they don’t think it applies to them.

        • I was too, once upon a time. Grew up in a CLEO home. Played with DEA NVG rigs as a child before they went out to kick doors. One of which held a record for the largest narc bust in history for a while. Ok to mention, since no one even remembers, and even Bernier & DARPA hadn’t yet conceived the web.

          Was downrange taking fire at age 9, house shot up pretty good trying to scare Dad off the trail by threatening his family. Also witnessed the transition first hand from Mayberry to militarized policing, to whatever the hell this even is these days.

          Used to be heavily pro, but balanced, not being blinded to the truth. Until they themselves tipped the scale with their own hands. Like you, chalked up the minor stuff to the same. Duly noted and assessed, then filed away till it became a bit too oft to ignore or discard.

          Their behavior with the aforementioned stalker was the bridge too far. No one threatens my families existence, nor aids and abets them.

          And then a paradigm shift occured with the realization your guv just sent a team to kill you. For. Taking. A. Fucking. Nap. Then colludes to sweep it all under the rug as though it never happened.

          Say their names…

          Et Al.

          Nothing quite like a true believer whose reality was shattered. Nearly having joined that list myself did rend all prior thought on the subject and rendered it crystalline.

          The irony isn’t just that they think id doesn’t apply to them, but more to that they believe themselves immune to, and far above it. The time to show the true level of the field is long past due, but also far from too late. Nor as far as some think, but the fear of it’s people is the right diagnosis. To a far greater degree than they already do.

          They aren’t all bad, no. But Back the Blue, indeed. Sic semper tyrannis.

  6. Hhhhmmmm. Seems the elephant in the room is overlooked: a blue state supreme court turned back a gun case, and instructed Bruen be the standard of review. Now, that’s different.

    • It’s getting scary out in the world. Courts are actually upholding the Constitution. Instead of mandating around it.

      • “Courts are actually upholding the Constitution. Instead of mandating around it.”

        Makes me very suspicious.

        Believe only half of what you hear, and none of what you see.

        • No elephant overlooked, Samual.

          Re-read my comment about the rush I get watching courts self-edit what they really want to do…

        • I suspect that at least a few courts have decent judges who are not ignorant of the abuse the police and DAs are directing towards the honest.

  7. @strych9
    “I suspect that at least a few courts have decent judges…”

    In blue states, regarding the 2A?

    • Every group has assholes. Every group that’s mostly assholes has a few decent people.

      I also suspect that judges are not entirely oblivious to the temperature of the country right now, so a few good judgements might be pure self-interest.

      A few of the major cases Conservatives were hot about two years back are, quite obviously, pure self interest on the part of the courts.

  8. @.40 cal Booger
    “political polling is among the biggest jokes ever perpetrated on the American people.”

    To be fair, designing really good surveys/polls is extremely difficult. Bias cannot be completely eradicated.

    My senior year in college, worked on the US Senate campaign for John Tower of Texas. The only use of polling was that we assumed that whatever polling indicated regarding Sen. Tower, his opponent was ahead by 10pts. Tower did win re-election.

  9. @Geoff PR
    “Re-read my comment about the rush I get watching courts self-edit what they really want to do…”

    That seems to happen with alleged “conservative” judges, but blue state judges? What do they fear that would drive one to go against the grain?

    Well, I guess Californication does have three “conservative” judges in a blue state.

  10. Thank goodness we had a good governor many years ago that got legislation passed that basically stated the inside of your car is an extension of your home. While there has been some discussion on a vehicle parked in a school parking lot, most of the feedback I have gotten is you are ok as long as it stays in your car. The article brings up some good points about many of these ‘sensitive area’ laws some states are passing. It basically denies concealed carry by restricting where a person can carry.

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