By Katherine Jeng

This report examines racial disparities in gun arrests, possessions, and violence, and how the criminalization of gun possession is producing mass incarceration. Gun violence is increasingly viewed as a major national problem and disproportionately impacts Black Americans. Yet current methods of reducing gun violence are failing and causing harm as gun violence continues to increase in the United States. This report analyzes two types of solutions from experts: the first type is recommendations to reform the gun industry, while the second is various gun diversion programs in cities across the United States. Furthermore, the report discusses the role of bipartisan support in gun reform policies. Lastly, this report analyzes how New York State Rifle and Pistol Association v. Kevin J. Bruen changed the framework for Second Amendment cases and long-standing laws.

Word count: 5,684

New York State Rifle & Pistol Association, Inc. v. Bruen is a landmark decision of the United States Supreme Court that expanded the power of the Second Amendment and altered the way gun possession cases are handled. With the outcome of this case, developing gun litigation is causing debate in headlines and courts. This paper was written from May to August 2023 under the direction of Nazgol Ghandnoosh, Ph.D. (Co-Director of Research, The Sentencing Project) to understand the current climate of guns in America and what solutions advocates must seek to combat the gun epidemic.

________________

Table of Contents

1. Executive Summary

2. Racial Disparities in Gun Licensing and Possession Cases

3. The Criminalization of Gun Possession Contributes to Mass Incarceration

4. Industry Reform, Gun Diversion Programs, and Alternative Sentencing

A. Gun Industry Reform

1. Repeal Gun Industry Immunity

2. Gun Seller Reform

3. Smart Guns and Gun Safety Features

4. Repeal Restrictions on Gun Trace Data

B. Gun Diversion Programs and Alternative Sentencing

C. Bipartisan Cooperation

5. A World Post-Bruen

________________

I. Executive Summary

Jasmine Phillips lawfully owned a gun in Texas but was charged with unlicensed

possession while visiting family in New York[1]. Even after her case was dismissed, she lost her custody of her child and her lease was terminated. Benjamin Prosser, who was carrying a gun for self-defense, was convicted of illegal gun possession and declared a “violent felon” by the New York penal code because he did not have a license[2]. Lastly, Sam Little was carrying a gun to protect his child when he was stopped by the police[3]. He had to drop out of classes from his associate’s program and spent eight months in jail. All three were clients of Bronx Defenders and mentioned in their amicus brief against New York’s concealed carry license law in New York State Rifle and Pistol Association v. Kevin J. Bruen. Despite exercising their Second Amendment rights, these clients suffered immense consequences.

This report examines racial disparities in gun arrests, possessions, and violence, and how the criminalization of gun possession is producing mass incarceration. Gun violence is increasingly viewed as a major national problem that disproportionately impacts Black Americans[4]. Yet current methods of reducing gun violence are failing and even causing harm as gun violence steadily increase in the United States[5]. This report analyzes two broad solutions from experts: the first is their recommendations to reform the gun industry, while the second solution involves various gun diversion programs in cities across the United States[6]. Furthermore, the report discusses how bipartisan support fits into these solutions. Lastly, this report analyzes how New York State Rifle and Pistol Association v. Kevin J. Bruen changed the framework for Second Amendment cases and long-standing laws.

II. Racial Disparities in Gun Licensing and Possession Cases

In November of 2021, the Supreme Court ruled on New York State Rifle and Pistol

Association v. Kevin J. Bruen, a case concerning New York State's proper concealed carry law. Robert Nash and Brandon Koch were rejected from their concealed-carry applications based on their inability to provide “proper cause.”[7]. Progressive organizations like the ACLU and NAACP wrote amicus briefs in support of New York’s choice to regulate public carry, with the latter stating that “public carry restrictions remain an important feature of states and localities’ public safety regimes today.”[8]. However, Bronx Defenders, Brooklyn Defender Services, and numerous other New York public defender offices wrote an opposing amicus brief stating that the denials violated the Second Amendment[9]. Citing cases like District of Columbia v. Heller and McDonald v. City of Chicago, the public defenders argued that the court’s precedent for firearm possession for self-defense was not the reality for their clients[10].

Before the ruling, acquiring a concealed-carry license was up to the sole discretion of the New York Police Department (NYPD). They had the ability to brand firearm possession as a crime or licensed right. The application process is often expensive and discretionary; the license costs about $400 in fees and an assessment of the “moral character” of the applicants[11]. As a result, the NYPD holds a preference for former police officers, who often get their fees waived and a “Good Guy” letter[12]. The letter is given to nearly all retiring full-duty cops, certifying that the applicant is “of good character” and able to continue carrying a gun. On the other hand, Robert Nash and Brandon Koch were denied from obtaining a license because they did not display “proper cause,” which is defined as demonstrating “a special need for self-protection distinguishable from that of the general community.”[13]. With this decision, the Supreme Court could invalidate this monopoly over gun licensing.

The language in New York’s penal law covers firearm-possession cases broadly, yet the consequences for these arrests are life-long. For example, if a firearm is not loaded but there is ammunition in the same area, it is considered “loaded.”[14]. If a firearm is in a car, “all persons” in the car possess it and can be charged. If a person possesses a gun without a license, then the law presumes they possessed it with “intent to use [it] unlawfully against another.”[15]. Altogether, simply owning a gun becomes a “violent felony.”[16].

Despite having a constitutional right to bear arms, the public defender’s clients face severe repercussions if charged with illegal gun possession. The ones charged are oftentimes physically threatened by police and held pretrial at Rikers[17]. As a result, many suffer from psychological trauma. Furthermore, people convicted of felony gun possession are branded as criminals and face a civil death: they may lose their jobs, custody of children, and immigration status and could face a year or more in prison[18]. Even if they avoid prison, they still suffer from damaging criminal records, legal fees, car impoundments, probation, and job loss[19].

Ultimately, with all these consequences, lawmakers have made the Second Amendment rights discriminatory towards African Americans[20]. The New York defenders stated in their brief, “Virtually all our clients whom New York prosecutes for exercising their Second Amendment right are Black or Hispanic. This is no accident. New York enacted its firearm licensing requirements to criminalize gun ownership by racial and ethnic minorities.”[21]. Despite making up only 18% of the population, Black New Yorkers make up 78% of the state’s felony gun possession cases[22]. On the other hand, white New Yorkers make up 70% of the population, but only 7% of cases[23]. In Chicago, The Marshall Project found that despite Black people making up less than a third of the population, more than 80% of people arrested for unlawful possession were Black[24]. In Houston, arrests for illegal possession jumped up 70% between 2019 and 2021, and, despite being less than 25% of the population, Black people made up more than 60% of those arrests[25]. In Cleveland, Black people accounted for nearly 90% of arrests for weapons-related charges in 2022[26]. We can see how these disparities play out in gun ownership, as white men are especially likely to be gun owners: 48% of white men say they own a gun, whereas only 24% of nonwhite men say they own a gun[27]. Only 24% of Black people report they own a gun as compared to 36% of white people[28].

In June 2022, Bruen was decided. The Supreme Court held, consistent with Heller and McDonald, that the State’s licensing requirements went against the Second and Fourteenth amendment[29]. However, it is unclear yet whether this ruling will affect racial discrimination in felony gun possession cases. In fact, the NYPD has been granting fewer gun possession licenses, leaving them pending after Bruen[30]. Furthermore, the NYPD reports that gun arrests have been at a historic high[31]. They indicated a significant increase in Queens and the

Bronx, both neighborhoods with clusters of Black New Yorkers[32]. Even still, New York State Rifle and Pistol Association v. Kevin J. Bruen and its ruling has become a catalyst for gun legislation and Second Amendment cases[33].

III. The Criminalization of Gun Possession Contributes to Mass Incarceration

Not only do laws that criminalize gun possession sustain mass incarceration but they are also ineffective at reducing the number of shootings on the streets or increasing solved investigations. In 2021, 72% of firearm convictions in Illinois were for possession offenses, and the state saw a 27% increase in prison admissions for firearm possession from 2014 to 2019[34]. A The Marshall Project report found that Illinois police made over 38,000 arrests for illegal gun possession in 2022, doubling from 2010[35]. Yet The Marshall Project found that as possession arrests increased, so did shootings—but the percentage of shooting victims where someone was arrested in their case declined[36]. Similar results were seen in Philadelphia. Whereas illegal gun possession arrests shot up more than 100% from 2015 to 2020, cases prosecuted by the District Attorney’s Office fell from 65% to 42%[37]. Clearance rates for fatal shootings, the percentage of cases solved by the Philadelphia Police Department, declined from 41% to 37% over the same period. Since 2010, Chicago police have failed to make an arrest in more than 8 in 10 shootings[38]. According to The Marshall Project, this may be because “investigating shootings used very different policing resources than the kinds of stops that result in gun possession arrests.”[39]

Focusing on gun possession is a misplacement of police resources. Roughly $557 billion in tax money per year pays for our country’s gun violence epidemic, which is around 2.6% of the U.S. Gross Domestic Product[40]. The Center for American Progress ran an analysis of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) and its budget from 2013 to 2020; during this time, funding for “firearms criminal use and possession” and “combating criminal organizations” grew from 36% of the overall budget whereas funding focused on “deterring illegal firearms trafficking/violent gun crime” and “diversion of firearms from legal commerce” were at 24% and 27%, respectively, and remained stagnant[41]. Everytown for Gun Safety is critical of the economic consequences of gun violence, stating, “Instead of funding education, social services, economic redevelopment grants, and so many other vital public goods from which we all benefit, we are spending precious funds on an epidemic that brings nothing of benefit and plenty of heartbreak and shattered lives.”[42]. The Center for American Progress, on the other hand, suggests an overhaul of ATP’s spending priorities for more effective gun violence prevention[43].

The focus on gun possession is deeply linked to race. Nevertheless, the disproportionate number of arrests of Black people do little to reduce gun violence. Chief public defender of Cook County, Illinois, Sharone Mitchell, states, “Laws criminalizing gun possession not only devastate Black and brown communities; they also fail to achieve one of their primary objectives: reducing the supply of guns on our streets.”[44]. There’s no shortage of guns on illegal markets, and access to them is far too easy. The Marshall Project echoes this sentiment, writing “disproportionate arrests of Black people for gun possession don’t directly address the violence that captivates headlines and moves policy: major mass shootings in schools, stores, houses of worship and nightclubs.”[45].

Not only do Black people overwhelmingly make up gun possession arrests, but Black communities in Chicago also remain the most affected by gun violence. The majority of gun deaths are Black men ages 20-30s[46]. Black people’s life expectancy is almost 10 years shorter on average than non-Black residents due to gun violence, as well as other factors like economic and health inequities[47]. Three in ten Black adults have personally witnessed someone being shot, one-third of Black adults have a family member who was killed by a gun, and one-third of Black adults say they worry either “every day,” or “almost every day” about themselves or someone they love being a victim of gun violence (compared to one in ten white adults)[48]. One in five Black adults feels like gun-related crimes, deaths, and injuries are a “constant threat” to their local community, more than double the share among white adults (8%)[49].

The rise in gun possession arrests mirrors the larger ineffectiveness and racially unjustness of other methods of the war on gun violence like “broken windows” policing, stop-and-frisk, and the war on drugs. A lawsuit was filed in 2012 deeming stop-and-frisks as unconstitutional in 2013[50]. While this decreased recorded stop-and-frisks by over 480,000 cases, there were still 92,383 stops and 60,583 frisks of people on the street between 2014 to 2017[51]. Worse, the racial disparities in these stops and frisks persisted. Of those numbers, 81% of stops and 84% of frisks were of Black or Latino people. 38% of all the “stops” were Black and Latino men from ages 14 to 24, though they only made up 5% of the population. Although being overrepresented in these stop-and-frisks, Black and Latino people were “less likely to be found with a weapon” than others[52]. The Marshall Project’s report, which focused on over 100 interviews in Chicago, found that researchers, attorneys, and advocates often compared the United States’ current approach to gun violence to the war on drugs[53]. These tough-on-crime policies are disproportionately affecting Black communities and inflating incarceration rates[54]. Ultimately, these forms of gun control (gun possession arrests and stop-and-frisks) end up sustaining mass incarceration[55].

IV. Industry Reform, Gun Diversion Programs, and Alternative Sentencing

To reduce gun violence, an exploration of alternative solutions that don't produce mass incarceration is critical. Punitive sentencing laws do little to curb gun violence, especially as sentences for gun-related offenses are more often for possession than actual acts of violence[56].

Instead, experts suggest a variety of methods. Sharone Mitchell Jr., Chief Public Defender of Cook County Illinois, recommends stemming the flow and use of guns by repealing gun industry immunity, educating gun owners on safe usage and storage, implementing targeted buybacks, prohibiting the manufacturing of assault weapons, and investing in gun violence prevention and restorative justice initiatives[57]. Everytown, Giffords, Brady United, the National Education Association, and others call for a ban on all assault weapons[58]. This memo will look at two other forms of gun policies: gun industry reform and gun diversion programs.

A. Gun Industry Reform

Multiple organizations like Everytown, Giffords, Center for American Progress, and The Trace have all criticized the gun industry and its special immunities[59]. Everytown suggests four recommendations to keep the gun industry accountable[60].

(1) Repeal Gun Industry Immunity

The gun manufacturing industry has obtained unprecedented immunity in America[61]. In 2005, President Bush signed the federal Protection of Lawful Commerce in Arms Act (PLCAA) into law, which shields gun manufacturers from liability and accountability[62]. The act prohibits plaintiffs from bringing “qualified civil liability actions” against these industry defendants who now have broad immunity from many common law tort actions[63].

However, the PLCAA also provides exceptions, including what has been called the “predicate exception.”[64]. The clause allows plaintiffs who were harmed to use civil actions against a gun industry defendant who has knowingly violated a statute of the sale or marketing of a firearm. This exception was used in Sandy Hook Elementary School’s $73 million settlement with Remington Arms Co[65]. The Connecticut Supreme Court held that one of the plaintiffs’ claims survived PLCAA’s bar. Although the case sparked hope in many against the immunity that the gun industry has, this strategy does little to open the door for more lawsuits against gun makers.

The gun industry is protected not only because of PLCAA but also by state immunity laws that have been adopted in some form in 34 states[66]. Similar to PLCAA, these immunity laws shield firearm and ammunition manufacturers, sellers, and other industry members from many kinds of traditional civil lawsuits. The immunity laws prohibit or deter cities or local governments from bringing lawsuits against gun industry defendants. Not only do Arkansas, Colorado, and Indiana, have these immunity statutes, but they also have laws that include punitive provisions to force victims who attempt to file lawsuits to pay for the gun industry’s legal fees[67].

The possibility of civil litigation can incentivize industries to make their products or business practices safer. Civil litigation is proven to better protect public health and safety, but currently, the gun industry has no reason to enact changes to make guns safer. Giffords and Everytown argue that PLCAA gives the gun business special protections unlike any others, and it should be repealed. PLCAA blocks legal responsibility for manufacturers that have failed to innovate and add safety features to guns and for sellers with irresponsible sales practices that contribute to illegal firearms in our communities. Gun manufacturers and sellers should abide by the same rules as every other industry and be held accountable when its actions result in harm. Nineteen states have already begun rejecting legal immunity for the gun industry[68]. In 2002, California was the first state to repeal a gun industry immunity statute that stated: “No firearm or ammunition shall be deemed defective in design on the basis that the benefits of the product do not outweigh the risk of injury.”[69]. In 2020, Virginia also repealed their statute followed by Delaware in 2022[70]. According to Giffords, in New York, Delaware, and California, laws were passed to allow a new cause of action authorizing any person harmed by a firearm industry member who has knowingly violated a statute surrounding the sale or marketing of a firearm to file suit and seek compensation or other fair remedies in court[71]. New Jersey holds a similar law but expressly authorizes only the state Attorney General to file lawsuits in these circumstances[72]. Giffords also states New York and California also empower certain local officials to bring civil lawsuits in their jurisdictions[73].

Everytown found that in 2022, California passed SB 1327, a first-of-its-kind legislation that allows individuals to sue anyone who violates certain California firearm laws, including those who make or sell illegal assault weapons or ghost gun parts, and those who sell guns to underage buyers[74]. California also enacted the Firearm Industry Responsibility Act in July 2023, which is a firearm industry standard of conduct in the Civil Code, complete with specific obligations and prohibitions that are unquestionably about the sale and marketing of firearms[75].

Repealing gun industry immunity provides many avenues of gun control. From keeping gun sellers and manufacturers accountable, increasing public and product safety, to deterring irresponsible business practices, there are many benefits to removing these special protections.

(2) Gun Seller Reform

In the United States, almost all firearms are sold by licensed sellers, including the ones recovered in crimes. Gun sellers are the essential connection between manufacturers and buyers. Yet policies around gun sellers have not been updated since the 1960s. The Gun Control Act of 1968 established a federal licensing system with requirements for firearms manufacturers, importers, pawnbrokers, collectors, and sellers, but did not significantly reduce crime or gun purchases[76]. Now, over 58,000 gun sellers in the United States are regulated by an act over 55 years old[77]. Furthermore, federal law does not require sellers to conduct business on commercial premises, which, in 1998, resulted in over 56% of all sellers operating out of their homes and 11% of all sellers operating out of businesses not normally associated with a gun business (like funeral homes and auto parts stores)[78]. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), the federal agency that regulates gun sellers, is underfunded and influenced by the gun industry[79]. This results in only 42% of sellers being inspected by ATF in a five-year period[80].

On the state level, only 26 states and the District of Columbia have adopted laws regulating firearms sellers[81]. Seventeen states require sellers to post and/or deliver written warnings to purchasers regarding the risks of storing firearms in a manner accessible to children.

Sixteen states and the District of Columbia generally require firearms sellers to obtain a state-issued license[82]. Even fewer states require firearms sellers to utilize security measures or background checks[83].

Everytown analyzed various investigations of gun sellers and revealed a majority of investigations of gun sellers had some violations like improper inventory, failing to complete required forms, and failing to conduct background checks[84]. Increasing supervision around gun sellers and creating gun seller reform would restrict dangerous transfers of firearms. Everytown found that intrastate gun trafficking was 64% lower in places with strong gun dealer regulations and oversight[85].

There has been increasing public support for comprehensive gun seller reform[86]. Giffords recommends a legislative framework to ameliorate such issues[87]. They recommend that sellers report all firearm sales, theft or loss, and physical inventory to law enforcement. Furthermore, Giffords calls for legislation to prohibit sellers in residential areas and require background checks or licenses for firearms sellers and seller employees. Ultimately, gun seller reform should consist of updating practices, increased record keeping, training, and holding sellers accountable.

(3) Smart Guns and Gun Safety Features

Roughly one gun is stolen every 90 seconds every day in the U.S[88]. This amounts to approximately 380,000 stolen guns every year. These guns often fall into an underground market, where people circumvent legal regulations to acquire them. Furthermore, guns are exempt from federal consumer product safety regulations, which means no agency can investigate alleged malfunctions, set mandatory manufacturing or design standards, or recall models found to be defective[89].

Authorized-use technology, safety features, and smart gun technology can stop unsanctioned gun use and theft. Much like how your phone scans your thumb, scans your face, or requires a passcode, the technology helps ensure a gun can only be fired by an authorized user[90]. Furthermore, Everytown suggests semi-automatic handgun models should have a loaded chamber indicator to visually show if a round is in the chamber, as well as a magazine safety disconnect to help prevent the gun from being fired unintentionally. All firearms should also meet childproof standards like higher trigger resistance or multiple motions to fire the gun. Three states already have a form of this legislation in place: Massachusetts, Maryland, and California require new handgun models to have childproofing features.

(4) Repeal Restrictions on Gun Trace Data

The Tiahrt Amendment of 2003 prohibits the release of gun trace data to anyone other than a law enforcement agency or a prosecutor. It was added by Todd Tiahrt, who argues that it protects the anonymity of undercover officers and the confidentiality of law enforcement investigations. This amendment is supported by the National Rifle Association (NRA)[91]. However, the reality is that the amendment restricts law enforcement from investigating gun crimes and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) from releasing firearm trace data or requiring gun sellers to submit inventories. Furthermore, the amendment restricts information investigators can obtain, like where a gun was purchased or who it was sold to. The FBI is also required to destroy records of approved background checks in 24 hours. The Tiahrt Amendment makes it hard for law enforcement to prosecute or solve gun crimes, and repealing these restrictions would aid in the enforcement of gun laws. Gun trace data, like gun sellers’ license revocations, are practices that could reduce the number of stolen or lost guns.

Repealing this amendment has received overwhelming support. Former and longest-serving New York City Police Department (NYPD) commissioner Raymond W. Kelly, wrote an opinion piece in the New York Times in 2007 on behalf of himself and “more than two dozen other law enforcement organizations, including the International Association of Chiefs of Police and a bipartisan coalition of 225 mayors” to oppose the reauthorization of the Tiahrt amendment[92].

Proponents of the Tiahrt amendment argue that public release of this data is a breach of privacy and could jeopardize criminal investigations. The National Shooting Sports Foundation states that repealing this amendment could jeopardize ongoing criminal investigations, putting the lives of law enforcement, witnesses and others at risk;[93] however, Everytown states that the amendment hinders law enforcement and contends that public safety must come first[94].

In 2015, Rep. Barbara Lee introduced a bill to repeal certain aspects of these amendments. She reintroduced the bill in 2018, and again in 2021 with Senator Bob Menendez[95]. The bill would repeal the prohibition on the ATF from releasing firearm trace data, the requirement for the FBI to destroy all approved gun purchaser records within 24 hours, and the prohibition on the ATF from requiring gun sellers to submit their inventories to law enforcement[96]. Furthermore, twelve states (Oregon, California, Illinois, North Carolina, Virginia, Pennsylvania, New York, Massachusetts, Connecticut, Delaware, Maryland, and New Jersey) require crime guns to be traced[97].

B. Gun Diversion Programs and Alternative Sentencing

Giffords recommends gun diversion programs as an alternative sentencing option for individuals with certain gun charges[98]. Gun diversion programs have become an increasingly popular rehabilitative approach to reducing the amount of gun crime in America. These programs use a variety of strategies such as community-based violence intervention and public health models to help people on a path to incarceration to exit the criminal legal system or avoid it entirely. Evidence of the results of these programs shows promising results. Cure Violence, also known as the "Interrupters Model," involves paying and training trusted members of a community to anticipate where violence will occur and intervene before it erupts[99]. A study released in 2014 found a 31% drop in homicides and a 19% decline in shootings in two Chicago districts where Interrupters worked[100]. Another program, the Youth and Community in Partnership (YCP), is an alternative sentencing program by Kings County District Attorney’s office in Brooklyn[101]. The results show that there is a 22% lower rearrest rate for 16-24 year old participants[102]. Moreover, Operation CeaseFire is a Chicago-based violence prevention program that focuses on affecting violence with a small number of selected community members. The program was implemented beyond Chicago, reaching Boston, Cincinnati, and Indianapolis. All these cities achieved reductions in gun homicide ranging from 25% to over 60%[103]. Lastly, Save Our Streets is a Brooklyn-located community-based project to address gun violence[104]. The program saw a 20% relative reduction in gun violence as the average monthly shooting rates in Crown Heights decreased by 6%, which compared to surrounding neighborhoods[105].

Giffords finds that although research supports diversion, many programs cannot demonstrate a positive impact on costs or savings because their focuses are on extremely low-level offenses[106]. The result is called net widening, where new treatments are more burdensome than some of the original consequences defendants faced. Giffords provides evidence that expanding diversion programming to felonies and more serious charges can be more effective and reduce net widening. They provide an evaluation of a Drug School program in Cook County, Illinois, that has separate tracks for individuals accused of misdemeanor and felony drug charges. Only 1% of those enrolled in felony Drug School received a jail sentence, as compared to 37% of those who did not opt for diversion[107].

Community-based violence intervention programs are growing rapidly throughout the United States and show promising results. A 2019 survey finds 55% of 220 prosecutors’ offices had diversion programming[108]. Giffords finds that diversion programs have the potential to be a proven method of reducing gun violence that does not contribute to mass incarceration. Increasing research shows that investing in and establishing these programs can allow for greater public safety.

C. Bipartisan Cooperation

Bipartisan cooperation is essential to address the deeply divisive issue of firearms regulation in a way that respects both individual rights and national safety. Consensus-driven policymaking is an essential way that legislation surrounding gun control is accepted and effective. The need for public safety, reducing gun violence, and stopping mass shootings must transcend party lines. Bipartisanship not only lends legitimacy to the resulting policies but also increases the likelihood of their successful implementation and enforcement. It is through the collaboration of lawmakers from both sides of the aisle that a balanced, evidence-based approach can be achieved to make our communities safer.

One example of successful bipartisan cooperation is the Bipartisan Safer Communities Act (BSCA) that President Joe Biden signed into law on June 25, 2022[109]. Both Democratic and Republican senators worked on this bill, including Connecticut Sen. Chris Murphy, Arizona Sen. Kyrsten Sinema, Texas Sen. John Cornyn, and North Carolina Sen. Thom Tillis. The Center for American Progress called it “the most significant gun violence reduction legislation in 30 years.”[110]. The BSCA prioritizes improving background checks by broadening the definition of licensed gun dealers and buyers under age 21. It furthermore increases access to mental health services, crisis intervention services, and community violence intervention programs. Lastly, it tightens criminal offenses for straw purchasing and trafficking. Lucy Sarkissian, a 19-year old gun survivor-activist, announced that one year after the BSCA passed, Colorado received more than $9 million to fund mental health care in schools and communities, support gun violence survivors, and to implement extreme risk protection orders. Although the BSCA is an amazing step in the right direction, we must continue off this momentum to continue bipartisan collaboration for gun safety[111].

V. A World Post-Bruen

New York State Rifle and Pistol Association v. Kevin J. Bruen altered our country’s approach to Second Amendment Rights in the legal system. Bruen has overturned a New York law created in 1913 that included “good moral character” and “proper cause” as conditions to public carry, expanding Second Amendment rights to more people[112]. Before Bruen, due to the Buffalo, New York shooting on May 14, 2022, New York had been taking steps to strengthen gun control[113]. Just seventeen days before Bruen was decided, New York Governor Kathy Hochul signed a 10-bill legislative package that bans the sale of semiautomatic rifles to people under 21, expands the definition of a firearm, restricts the sale of body armor to specific professions, broadens the list of people who can file an Extreme Risk Protection Order, and publishes requirements for social media platforms to bolster their hateful conduct policies[114].

However, the Bruen case is already having ripple effects in other states, reversing the tide of gun control laws. California Attorney General Rob Bonta released a legal memo a day after the Bruen ruling stating that the “good cause” requirements in the California Penal Code are unconstitutional[115]. The Massachusetts Attorney General released a joint advisory with the Executive Office of Public Safety and Security to “cease enforcement of the ‘good reason’ provision of the license-to-carry statute in response to Bruen.”[116]. Maryland removed their “good and substantial reason” requirements for concealed carry[117]. Gov. Hochul signed the Concealed Carry Improvement Act into law on July 1, 2022[118]. Hawaii passed legislation to allow more people to carry concealed firearms, following similar steps as New Jersey and New York[119].

Bruen has allowed for has further stirred up new debate regarding the dismissal of federal felon-in-possession prosecutions, creating new legal inconsistencies between federal and state rulings.. In June 2023, a year after Bruen, District Judge Carlton Reeves dismissed Jessie Bullock’s criminal charges for owning a firearm despite a felony conviction in United States v. Bullock[120]. He ruled that prohibiting Bullock from owning a gun because of a conviction would violate the Second Amendment. Although Reeves is bound to the law and decision from the Supreme Court, he has been vocal about his disapproval. In October 2022, Reeves strongly criticized the Supreme Court’s Bruen decision, which ruled that gun laws should depend on whether they are consistent with the “history and tradition” of restrictions in place at the time the Constitution was written[121]. He stated the Supreme Court needed a “trained historian” to help understand gun laws[122]. He cites disagreement about the Second Amendment and heavy criticism of Bruen among historians. The Washington Post states Reeves “calls the Supreme Court’s bluff on guns.”[123]. Through this ruling, it is evident that Bruen “has created quite the mess” and leads to many questions that judges now must decide[124].

As another example, Zackey Rahimi was arrested after police found a gun in his home. He was involved in five shootings and has a restraining order against him due to domestic violence. He was convicted on the grounds of the 1994 federal law that prohibits firearm possession for subjects of restraining orders. However, after Bruen, he is appealing his indictment in United States v. Rahimi. He argued that Bruen overturned the previous law and therefore his indictment is unconstitutional[125]. The case has made its way to the Supreme Court and is pending. Everytown calls the decision “extremely dangerous for women in America” and advocates for the decision to be immediately vacated or reversed[127].

Yet there’s still hope with this Supreme Court decision. The Justice Department and the Biden administration are asking the court to revoke the lower court ruling[128]. NBC News calls it the “first real test of how broadly the court’s conservative majority wants its 2022 ruling to be interpreted”, referring to Bruen[129].

Furthermore, progress on gun reform continues as some states refuse to back down from gun control because of Bruen. Connecticut’s Office of the Attorney General acknowledged Bruen and its impact on Connecticut’s gun laws but released a statement saying the office “is ready to aggressively defend Connecticut’s laws and our right to protect the safety of all our citizens.”[130]. Moreover, in July 2023, California Governor Gavin Newsom proposed a constitutional amendment on gun safety. It aims to do four things: ban assault weapons, mandate background checks on gun buyers, implement a waiting period, and add a minimum purchasing age of 21. The Los Angeles Times applauds Newsom for offering something “more muscular than the typical thoughts-and-prayers response”, yet simultaneously acknowledges that this amendment would have “no chance of being adopted.”[131].

Massachusetts House Judiciary Chairman Michael Day criticized the “rogue Supreme Court” and filed a large gun reform bill in June 2023 that would help “ensure the health and safety of [Massachusetts] residents.”[132]. The bill expands the state’s Extreme Risk Protection Order (ERPO), otherwise known as the “Red Flag” law[133]. The law directs a person to surrender their license to carry. The bill also focuses on controlling ghost guns by requiring two essential gun parts, receivers and barrels, to be registered and have serial numbers. Furthermore, it updates the state’s concealed carry law to prohibit licensed gun owners from carrying firearms in schools, colleges, universities, government buildings, polling places, and private property[134]. The Boston Globe applauds this bill, declaring, “Making Massachusetts safer is the best we can hope for. This legislation helps get us there.”[135].

The decision of New York State Rifle & Pistol Assn., Inc. v. Bruen has fundamentally changed the constitutionality and methodology of gun laws. It has distorted historical precedent to radically expand the Second Amendment right in the face of epidemic gun violence. Ultimately, the decision compels us to ask: how effective are our current solutions to gun violence, and how must we rethink them? We are now living in a pivotal moment of gun legislation and must advocate, with bated breath, for effective gun regulation.

________________

Endnotes

1 New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

2 New York State Rifle & Pistol Ass’n, Inc. v. Bruen.

3 New York State Rifle & Pistol Ass’n, Inc. v. Bruen.

4. Pew Research Center, “Large Majority of Americans Support Raising Minimum Age for Buying Guns to 21,” June 27, 2023, https://www.pewresearch.org/politics/2023/06/28/gun-violence-widely-viewed-as-a-major-and-growing-national-problem/pp_2023-06-28_gun-violence_00-04/.

5. Pew Research Center, “What the Data Says about Gun Deaths in the U.S.,” April 26, 2023, https://www.pewresearch.org/short-reads/2023/04/26/what-the-data-says-about-gun-deaths-in-the-u-s/.

6. Everytown, “Lack of Gun Industry Accountability,” 2023, https://www.everytown.org/issues/lack-of-gun-industry-accountability/.

7. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

8. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

9. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

10. District of Columbia v. Heller was a landmark decision where the Supreme Court found a District of Columbia law strictly regulating gun ownership to be unconstitutional. McDonald v. City of Chicago was a landmark decision where the Supreme Court ruled that the 14th Amendment requires state and local governments to respect the Second Amendment.

11. “New Application Instructions · Government Portal,” accessed August 24, 2023, https://licensing.nypdonline.org/new-app-instruction/?AspxAutoDetectCookieSupport=1.

12. “NYPD ‘Good Guy’ Note Let Suspect Pack Heat,” accessed August 24, 2023, https://nypost.com/2006/05/18/nypd-good-guy-note-let-suspect-pack-heat/.

13. National League of Cities, “SCOTUS Strikes Down ‘Proper Cause’ Requirement to Carry a Gun in Public,” June 24, 2022, https://www.nlc.org/article/2022/06/24/scotus-strikes-down-proper-cause-requirement-to-carry-a-gun-in-public/.

14. NY Law, “Article 265 Penal Law Firearms - Dangerous Weapons,” accessed August 24, 2023, https://ypdcrime.com/penal.law/article265.php.

15. NY Law, “Article 265 Penal Law Firearms - Dangerous Weapons,” accessed August 24, 2023, https://ypdcrime.com/penal.law/article265.php.

16. NY Law, “Article 265 Penal Law Firearms - Dangerous Weapons,” accessed August 24, 2023, https://ypdcrime.com/penal.law/article265.php.

17. Avinash Samarth, Aimee Carlisle, Christopher Smith, Michael Thomas, and Meghna Philip, "We Are Public Defenders. New York’s Gun Laws Eviscerate Our Clients’ Second Amendment Rights," SCOTUSblog, October 28, 2021, https://www.scotusblog.com/2021/10/we-are-public-defenders-new-yorks-gun-laws-eviscerate-our-clients-second-amendment-rights/.

18. Avinash Samarth, Aimee Carlisle, Christopher Smith, Michael Thomas, and Meghna Philip, "We Are Public Defenders. New York’s Gun Laws Eviscerate Our Clients’ Second Amendment Rights," SCOTUSblog, October 28, 2021, https://www.scotusblog.com/2021/10/we-are-public-defenders-new-yorks-gun-laws-eviscerate-our-clients-second-amendment-rights/.

19. Lakeidra Chavis and Geoff Hing, “5 Things to Know About the Failed War on Gun Violence,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-what-to-know.

20. This report uses the terms Black and African American interchangeably.

21. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

22. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

23. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

24. Lakeidra Chavis and Geoff Hing, “5 Things to Know About the Failed War on Gun Violence,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-what-to-know.

25. Lakeidra Chavis and Geoff Hing, “5 Things to Know About the Failed War on Gun Violence,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-what-to-know.

26. Lakeidra Chavis and Geoff Hing, “5 Things to Know About the Failed War on Gun Violence,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-what-to-know.

27. Travis Mitchell, “The Demographics of Gun Ownership,” Pew Research Center’s Social & Demographic Trends Project (blog), June 22, 2017, https://www.pewresearch.org/social-trends/2017/06/22/the-demographics-of-gun-ownership/.

28. Travis Mitchell, “The Demographics of Gun Ownership,” Pew Research Center’s Social & Demographic Trends Project (blog), June 22, 2017, https://www.pewresearch.org/social-trends/2017/06/22/the-demographics-of-gun-ownership/.

29. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

30. Gwynne Hogan and Suhail Bhat, “NYPD Granting Fewer Gun Permits After Supreme Court Ruled It Had to Grant More, Data Shows,” The City, July 23, 2023, https://www.thecity.nyc/2023/7/23/23803195/nypd-gun-permit-approvals-bruen-supreme-court-ghost.

31. “NYPD Announces Citywide Crime Statistics for June 2023.”

32. “NYPD Announces Citywide Crime Statistics for November 2022”

33. See Section V. A World Post-Bruen.

34. David E. Olson et al., “Sentences Imposed on Those Convicted of Felony Illegal Possession of a Firearm in Illinois,” 3.

35. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

36. Lakeidra Chavis and Geoff Hing, “5 Things to Know About the Failed War on Gun Violence,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-what-to-know.

37. Sarah Bedford, “Democrats Call for More Gun Laws despite Not Enforcing the Ones They Have,” Washington Examiner, April 20, 2023, https://www.washingtonexaminer.com/restoring-america/fairness-justice/democrats-want-more-gun-laws-dont-enforce-ones-they-have.

38. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

39. Geoff Hing and Lakeidra Chavis, “How We Reported on Rising Gun Possession Arrests,” The Marshall Project, May 3, 2023, https://www.themarshallproject.org/2023/05/03/how-we-reported-on-rising-gun-possession-arrests.

40. “The Economic Cost of Gun Violence,” July 19, 2022. https://everytownresearch.org/report/the-economic-cost-of-gun-violence/.

41. Chelsea Parsons, Eugenio Weigend Vargas, and Rukmani Bhatia, “Rethinking ATF’s Budget to Prioritize Effective Gun Violence Prevention,” Center for American Progress, September 17, 2020, https://www.americanprogress.org/article/rethinking-atfs-budget-prioritize-effective-gun-violence-prevention/.

42. Everytown, “The Economic Cost of Gun Violence,” July 19, 2022. https://everytownresearch.org/report/the-economic-cost-of-gun-violence/.

43. Chelsea Parsons, Eugenio Weigend Vargas, and Rukmani Bhatia, “Rethinking ATF’s Budget to Prioritize Effective Gun Violence Prevention,” Center for American Progress, September 17, 2020, https://www.americanprogress.org/article/rethinking-atfs-budget-prioritize-effective-gun-violence-prevention/.

44. Sharone Mitchell Jr., “There’s No Second Amendment on the South Side of Chicago,” The Nation, November 12, 2021, https://www.thenation.com/article/politics/gun-control-supreme-court/.

45. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

46. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

47. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

48. "Americans’ Experiences with Gun-Related Violence, Injuries, And Deaths," accessed September 19, 2023, https://www.kff.org/other/poll-finding/americans-experiences-with-gun-related-violence-injuries-and-deaths/.

49. "Americans’ Experiences with Gun-Related Violence, Injuries, And Deaths," accessed September 19, 2023, https://www.kff.org/other/poll-finding/americans-experiences-with-gun-related-violence-injuries-and-deaths/.

50. New York Civil Liberties Union, “Stop-and-Frisk Data,” January 2, 2012, https://www.nyclu.org/en/stop-and-frisk-data.

51. New York Civil Liberties Union, “Stop-and-Frisk Data,” January 2, 2012, https://www.nyclu.org/en/stop-and-frisk-data.

52. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022).

53. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

54. Lakeidra Chavis and Geoff Hing, “The War on Gun Violence Has Failed. And Black Men Are Paying the Price,” The Marshall Project, March 23, 2023, https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago.

55. James Forman Jr., Locking Up Our Own: Crime and Punishment in Black America, n.d.

56. Austin Fisher, “Harsher Sentences Do Not Reduce Gun Violence, Research Shows,” Source New Mexico (blog), February 2, 2022, https://sourcenm.com/2022/02/02/harsher-sentences-do-not-reduce-gun-violence-research-shows/.

57. Sharone Mitchell Jr., “There’s No Second Amendment on the South Side of Chicago,” November 12, 2021, https://www.thenation.com/article/politics/gun-control-supreme-court/.

58. “Prohibit Assault Weapons”; “Assault Weapons”; “Demand a Ban on Assault Weapons”; “Ban Assault Weapons”

59. “Lack of Gun Industry Accountability”; Center for American Progress, “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021, https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-immunity/.; “Frequently Asked Questions About Gun Industry Immunity”; Kohrman, “States May Have Found a Way Through the Gun Industry’s Liability Shield.”

60. “Lack of Gun Industry Accountability”; Center for American Progress, “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021, https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-immunity/.; “Frequently Asked Questions About Gun Industry Immunity”; Kohrman, “States May Have Found a Way Through the Gun Industry’s Liability Shield.”

61. Center for American Progress, “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021, https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-immunity/.

62. Sen. Larry E. Craig [R-ID], “Text - S.397 - 109th Congress (2005-2006): Protection of Lawful Commerce in Arms Act,” Legislation, October 26, 2005, http://www.congress.gov/bill/109th-congress/senate-bill/397/text.

63. Sen. Larry E. Craig [R-ID], “Text - S.397 - 109th Congress (2005-2006): Protection of Lawful Commerce in Arms Act,” Legislation, October 26, 2005, http://www.congress.gov/bill/109th-congress/senate-bill/397/text.

64. Sen. Larry E. Craig [R-ID], “Text - S.397 - 109th Congress (2005-2006): Protection of Lawful Commerce in Arms Act,” Legislation, October 26, 2005, http://www.congress.gov/bill/109th-congress/senate-bill/397/text.

65. Chan, “Why It’s So Difficult to Sue Gun Makers, Despite Sandy Hook.”

66. Center for American Progress, “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021, https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-immunity/.

67. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

68. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

69. “Gun Industry Immunity in California,” January 5, 2023, https://giffords.org/lawcenter/state-laws/gun-industry-immunity-in-california/#footnote_0_14451.

70. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

71. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

72. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

73. Giffords, “Gun Industry Immunity,” accessed September 19, 2023, https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

74. Everytown, “VICTORY FOR GUN SAFETY: Following Tireless Advocacy From Moms Demand Action And Students Demand Action, Governor Newsom Signs First-Of-Its-Kind Gun Safety Bill,” July 22, 2022, https://www.everytown.org/press/victory-for-gun-safety-following-tireless-advocacy-from-moms-demand-action-and-students-demand-action-governor-newsom-signs-first-of-its-kind-gun-safety-bill/.

75. “Gun Industry Immunity in California,” January 5, 2023, https://giffords.org/lawcenter/state-laws/gun-industry-immunity-in-california/#footnote_0_14451

76. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

77. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

78. “Report of Active Firearms Licenses,” Bureau of Alcohol, Tobacco, Firearms and Explosives, January 10, 2020.

79. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

80. David Chipman, “MEMO: ATF at a Time of Transition”; Buckles, “Commerce in Firearms in the United States.”; “Review of ATF’s Federal Firearms Licensee Inspection Program.”

81. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

82. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

83. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

84. Everytown, “Gun Dealer Reform,” accessed September 19, 2023, https://www.everytown.org/solutions/gun-dealer-reform/.

85. Everytown, “Gun Dealer Reform,” accessed September 19, 2023, https://www.everytown.org/solutions/gun-dealer-reform/.

86. Colleen L. Barry, Elizabeth M. Stone, Cassandra K. Crifasi, Jon S. Vernick, Daniel W. Webster, and Emma E. McGinty, "Trends In Public Opinion on US Gun Laws: Majorities Of Gun Owners and Non–Gun Owners Support a Range of Measures," Health Affairs (Project Hope) 38, no. 10 (October 2019): 1727–34, https://doi.org/10.1377/hlthaff.2019.00576.

87. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/.

88. David Hemenway, Deborah Azrael, and Matthew Miller, “Whose Guns Are Stolen? The Epidemiology of Gun Theft Victims,” Injury Epidemiology 4 (April 10, 2017): 11, https://doi.org/10.1186/s40621-017-0109-8.

89. Champe Barton, "Lawmakers Push for Guns to Be Regulated Like Other Products," The Trace, April 27, 2023, https://www.thetrace.org/2023/04/congress-gun-safety-bills-cpsc-sig-sauer/.

90. Everytown, “Smart Guns and Gun Safety Features,” accessed August 24, 2023, https://www.everytown.org/solutions/smart-guns-and-gun-safety-requirements/.

91. Raymond W. Kelly, “Washington’s Secret Gun Files,” The New York Times, June 16, 2007, sec. Opinion.

92. Giffords, “Tiahrt Amendments,” accessed August 24, 2023, https://giffords.org/lawcenter/gun-laws/policy-areas/other-laws-policies/tiahrt-amendments/.

93. "Biden’s Dangerous Gun Control Plans: Repealing Tiahrt," NSSF, accessed October 24, 2023, https://www.nssf.org/articles/bidens-dangerous-gun-control-plans-repealing-tiahrt/.

94. Everytown. "Repeal Restrictions on Gun Trace Data." Accessed August 24, 2023. https://everytownresearch.org/solution/gun-trace-data/.

95. Barbara Lee - Congresswoman for the 12th District of California, "Rep. Lee, Sen. Menendez Reintroduce Bicameral Bill to End NRA-Backed Ban on Preservation, Disclosure of Gun Records," March 25, 2021, https://lee.house.gov/news/press-releases/rep-lee-sen-menendez-reintroduce-bicameral-bill-to-end-nra-backed-ban-on-preservation-disclosure-of-gun-records.

96. Barbara Lee - Congresswoman for the 12th District of California, "Rep. Lee, Sen. Menendez Reintroduce Bicameral Bill to End NRA-Backed Ban on Preservation, Disclosure of Gun Records," March 25, 2021, https://lee.house.gov/news/press-releases/rep-lee-sen-menendez-reintroduce-bicameral-bill-to-end-nra-backed-ban-on-preservation-disclosure-of-gun-records..

97. Everytown. "Repeal Restrictions on Gun Trace Data." Accessed August 24, 2023. https://everytownresearch.org/solution/gun-trace-data/.

98. Everytown Research & Policy, “Crime Gun Tracing,” accessed August 24, 2023, https://everytownresearch.org/rankings/law/crime-gun-tracing/.

99. Giffords, “A Second Chance: The Case for Gun Diversion Programs,” December 7, 2021, https://giffords.org/lawcenter/report/a-second-chance-the-case-for-gun-diversion-programs/.

100. “Cure Violence Evidence Summary”

101. David B. Henry, Shannon Knoblauch, and Rannveig Sigurvinsdottir, “The Effect of Intensive CeaseFire Intervention on Crime in Four Chicago Police Beats: Quantitative Assessment.”

102. “Youth Diversion”

103. Giffords, “A Second Chance: The Case for Gun Diversion Programs,” December 7, 2021, https://giffords.org/lawcenter/report/a-second-chance-the-case-for-gun-diversion-programs/.

104. “Operation Ceasefire and the Safe Community Partnership.”

105. Sarah Picard-Fritsche and Lenore Cerniglia, “Testing a Public Health Approach to Gun Violence,” Center for Court Innovation, 2012.

106. Sarah Picard-Fritsche and Lenore Cerniglia, “Testing a Public Health Approach to Gun Violence,” Center for Court Innovation, 2012.

107. Giffords, “A Second Chance: The Case for Gun Diversion Programs,” December 7, 2021, https://giffords.org/lawcenter/report/a-second-chance-the-case-for-gun-diversion-programs/.

108. Giffords, “A Second Chance: The Case for Gun Diversion Programs,” December 7, 2021, https://giffords.org/lawcenter/report/a-second-chance-the-case-for-gun-diversion-programs/.

109. Michela Lowry and Ashmini Kerodal, “Prosecutor-Led Diversion.”

110. Margaret Finerty, “The Supreme Court’s Bruen Decision and Its Impact: What Comes Next?” New York State Bar Association, August 9, 2022, https://nysba.org/the-supreme-courts-bruen-decision-and-its-impact-what-comes-next/.

111. Margaret Finerty, “The Supreme Court’s Bruen Decision and Its Impact: What Comes Next?” New York State Bar Association, August 9, 2022, https://nysba.org/the-supreme-courts-bruen-decision-and-its-impact-what-comes-next/.

112. Margaret Finerty, “The Supreme Court’s Bruen Decision and Its Impact: What Comes Next?” New York State Bar Association, August 9, 2022, https://nysba.org/the-supreme-courts-bruen-decision-and-its-impact-what-comes-next/..

113. “Legal Alert OAG 2022 02.” California Department of Justice Office of the Attorney General, February 2022.

114. “Joint Advisory Regarding the Massachusetts Firearms Licensing System After the Supreme Court’s Decision in New York State Rifle & Pistol Association v. Bruen,” Massachusetts Attorney General’s Office and the Executive Office of Public Safety and Security, 2022.

115. "Bipartisan Safer Communities Act," Office of Elementary and Secondary Education, accessed October 24, 2023, https://oese.ed.gov/bipartisan-safer-communities-act/.

116. Nick Wilson, Chandler Hall, Allison Jordan, “The Bipartisan Safer Communities Act, 1 Year Later”. Center for American Progress. https://www.americanprogress.org/article/the-bipartisan-safer-communities-act-1-year-later/.

117. Young Activists Call for Reforms to Combat Gun Violence | C-SPAN.org. (n.d.). Retrieved October 24, 2023, from https://www.c-span.org/video/?c5074816/young-activists-call-reforms-combat-gun-violence.

118. Lawlor, “Maryland Court Follows Supreme Court’s Gun Permit Ruling.”

119. Margaret Finerty, “The Supreme Court’s Bruen Decision and Its Impact: What Comes Next?” New York State Bar Association, August 9, 2022, https://nysba.org/the-supreme-courts-bruen-decision-and-its-impact-what-comes-next/.

120. McAvoy, “Hawaii Allows More Concealed Carry after US Supreme Court Ruling, but Bans Guns in Most Places”; “New Jersey Governor Signs Bill Overhauling Gun Carry Rules”; Hill, Khan, and Caina Calvan, “New York to Restrict Gun Carrying after Supreme Court Ruling.”

121. “Reeves Order”

122. Marcus, Ruth. “A U.S. District Judge Calls the Supreme Court’s Bluff on Guns.” Washington Post , July 8, 2023.

123. https://www.washingtonpost.com/opinions/2023/07/07/originalism-supreme-court-seco nd-amendment-reeves/.

124. ABA Journal. “In ‘scorching’ Opinion, Federal Judge Considers Appointing Historian to Help Him in Gun Case.” Accessed September 19, 2023. https://www.abajournal.com/news/article/in-scorching-opinion-federal-judge-considers- appointing-historian-to-help-him-in-gun-case.

125. Marcus, Ruth. “A U.S. District Judge Calls the Supreme Court’s Bluff on Guns.” Washington Post , July 8, 2023. https://www.washingtonpost.com/opinions/2023/07/07/originalism-supreme-court-seco nd-amendment-reeves/.

126. Marcus, Ruth. “A U.S. District Judge Calls the Supreme Court’s Bluff on Guns.” Washington Post , July 8, 2023. https://www.washingtonpost.com/opinions/2023/07/07/originalism-supreme-court-seco nd-amendment-reeves/.

127. Fritze, “Guns for Domestic Abusers?”; “1117. Restrictions on the Possession of Firearms by Individuals Convicted of a Misdemeanor Crime of Domestic Violence.”

128. “Opinion: The Fifth Circuit’s Rahimi decision protects abusers’ access to guns. The Supreme Court must act to protect survivors of domestic violence.”

129. Everytown. “United States v. Rahimi: The Fifth Circuit’s Dangerous and Extreme Decision,” February 8, 2023. https://www.everytown.org/united-states-v-rahimi-the-fifth-circuits-dangerous-and-extr eme-decision/.

130. Reuters. “DOJ Asks Supreme Court to Uphold Domestic Violence Gun Law.” NBC News, March 18, 2023. https://www.nbcnews.com/politics/supreme-court/justice-department-asks-supreme-cou rt-uphold-domestic-violence-gun-law-rcna75606.

131. Reuters. “DOJ Asks Supreme Court to Uphold Domestic Violence Gun Law.” NBC News, March 18, 2023. https://www.nbcnews.com/politics/supreme-court/justice-department-asks-supreme-cou rt-uphold-domestic-violence-gun-law-rcna75606..

132. Dave Altimari, "Supreme Court Gun Ruling Could Prompt ‘wave of New Litigation’ in CT," CT Mirror, June 23, 2022, http://ctmirror.org/2022/06/23/wave-of-new-litigation-in-ct-possible-after-supreme-court-gun-law-ruling/.

133. Los Angeles Times. “Editorial: Newsom Gun Amendment Is a Non-Starter, but It Still Has Value,” July 17, 2023. https://www.latimes.com/opinion/story/2023-07-17/newsom-gun-amendment-non-starter.

134. BostonGlobe.com. “Five Days, 26 US Mass Shootings. Here’s a Proposal to Slow the Bloodshed.,” July 10, 2023. https://www.bostonglobe.com/2023/07/10/opinion/mass-shootings-gun-safety-legislatio n-ghost-guns-red-flag-law/.

135. Mass.gov. “Extreme Risk Protection Orders.” Accessed September 19, 2023. https://www.mass.gov/extreme-risk-protection-orders.

136. BostonGlobe.com. “Five Days, 26 US Mass Shootings. Here’s a Proposal to Slow the Bloodshed.,” July 10, 2023. https://www.bostonglobe.com/2023/07/10/opinion/mass-shootings-gun-safety-legislatio n-ghost-guns-red-flag-law/.

References

ABA Journal. “In ‘scorching’ Opinion, Federal Judge Considers Appointing Historian to Help Him in Gun Case.” Accessed September 19, 2023. https://www.abajournal.com/news/article/in-scorching-opinion-federal-judge-considers- appointing-historian-to-help-him-in-gun-case.

“Aim4Peace Evaluation Brief Report 2018-2020.” Aim4Peace, 2020.

Altimari, Dave. “Supreme Court Gun Ruling Could Prompt ‘wave of New Litigation’ in CT.” CT Mirror, June 23, 2022. http://ctmirror.org/2022/06/23/wave-of-new-litigation-in-ct-possible-after-supreme-cour t-gun-law-ruling/ .

“Americans’ Experiences with Gun-Related Violence, Injuries, And Deaths.” Accessed September 19, 2023.

https://www.kff.org/other/poll-finding/americans-experiences-with-gun-related-violenc e-injuries-and-deaths/ .

AP News. “New Jersey Governor Signs Bill Overhauling Gun Carry Rules,” December 22, 2022. https://apnews.com/article/new-jersey-phil-murphy-413d6205f23a715290db75300b89d

1fb .

Avinash Samarth, Aimee Carlisle, Christopher Smith, Michael Thomas, and Meghna Philip. “We Are Public Defenders. New York’s Gun Laws Eviscerate Our Clients’ Second Amendment Rights.” SCOTUSblog, October 28, 2021. https://www.scotusblog.com/2021/10/we-are-public-defenders-new-yorks-gun-laws-evi scerate-our-clients-second-amendment-rights/ .

“Ban Assault Weapons.” Accessed September 19, 2023.

https://www.nea.org/advocating-for-change/action-center/take-action/ban-assault-weap ons .

Barbara Lee - Congresswoman for the 12th District of California. “Rep. Lee, Sen. Menendez Reintroduce Bicameral Bill to End NRA-Backed Ban on Preservation, Disclosure of Gun Records,” March 25, 2021. https://lee.house.gov/news/press-releases/rep-lee-sen-menendez-reintroduce-bicameral- bill-to-end-nra-backed-ban-on-preservation-disclosure-of-gun-records .

Barry, Colleen L., Elizabeth M. Stone, Cassandra K. Crifasi, Jon S. Vernick, Daniel W.

Webster, and Emma E. McGinty. “Trends In Public Opinion on US Gun Laws:

Majorities Of Gun Owners and Non–Gun Owners Support a Range of Measures.”

Health Affairs (Project Hope) 38, no. 10 (October 2019): 1727–34.

https://doi.org/10.1377/hlthaff.2019.00576 .

Barton, Champe. “Lawmakers Push for Guns to Be Regulated Like Other Products.” The Trace, April 27, 2023.

https://www.thetrace.org/2023/04/congress-gun-safety-bills-cpsc-sig-sauer/ .

Biden’s Dangerous Gun Control Plans: Repealing Tiahrt • NSSF. (n.d.). Retrieved October 24, 2023, from https://www.nssf.org/articles/bidens-dangerous-gun-control-plans-repealing-tiahrt/

Bipartisan Safer Communities Act. (n.d.). Office of Elementary and Secondary Education. Retrieved October 24, 2023, from https://oese.ed.gov/bipartisan-safer-communities-act/

BostonGlobe.com. “Five Days, 26 US Mass Shootings. Here’s a Proposal to Slow the Bloodshed.,” July 10, 2023.

https://www.bostonglobe.com/2023/07/10/opinion/mass-shootings-gun-safety-legislatio n-ghost-guns-red-flag-law/ .

Brady. “Demand a Ban on Assault Weapons.” Accessed September 19, 2023.

https://www.bradyunited.org/act/ban-assault-weapons .

Buckles, Bradley A. “Commerce in Firearms in the United States.” Department of the Treasury, February 2000.

———. “The Bureau of Alcohol, Tobacco, and Firearms (ATF) Submits This Report on Its

Activities Relating to the Regulation of Firearms during the Calendar Year 1999. This Report Is Submit- Ted in Accordance with ATF’s Mission of Informing the Public.,” n.d.

Butts, Jeffrey A., Caterina Gouvis Roman, Lindsay Bostwick, and Jeremy R. Porter. “Cure Violence: A Public Health Model to Reduce Gun Violence.” Annual Review of Public Health 36, no. 1 (2015): 39–53.

https://doi.org/10.1146/annurev-publhealth-031914-122509 .

Center for American Progress. “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021.

https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-imm unity/ .

Chan, Melissa. “Why It’s So Difficult to Sue Gun Makers, Despite Sandy Hook,” February 18, 2022. https://time.com/6149343/sandy-hook-remington-other-gun-lawsuits/ .

Chavis, Lakeidra, and Geoff Hing. “5 Things to Know About the Failed War on Gun Violence.” The Marshall Project, March 23, 2023.

https://www.themarshallproject.org/2023/03/23/gun-laws-violence-chicago-policing-wh at-to-know .

———. “The War on Gun Violence Has Failed. And Black Men Are Paying the Price.” The Marshall Project, March 23, 2023.

https://www.themarshallproject.org/2023/03/23/gun-violence-possession-police-chicago

.

Chelsea Parsons, Eugenio Weigend Vargas, and Rukmani Bhatia. “Rethinking ATF’s Budget to Prioritize Effective Gun Violence Prevention.” Center for American Progress, September 17, 2020.

https://www.americanprogress.org/article/rethinking-atfs-budget-prioritize-effective-gu n-violence-prevention/ .

City of New York. “NYPD Announces Citywide Crime Statistics for June 2023,” July 6, 2023.

https://www.nyc.gov/site/nypd/news/p00084/nypd-citywide-crime-statistics-june-2023 .

City of New York. “NYPD Announces Citywide Crime Statistics for November 2022,” December 5, 2022.

https://www.nyc.gov/site/nypd/news/p00070/nypd-citywide-crime-statistics-november-

2022 .

Craig, Larry E. S.397 - 109th Congress (2005-2006): Protection of Lawful Commerce in Arms Act, 109-92 § (2005).

https://www.congress.gov/bill/109th-congress/senate-bill/397/text .

David B. Henry, Shannon Knoblauch, and Rannveig Sigurvinsdottir. “The Effect of Intensive CeaseFire Intervention on Crime in Four Chicago Police Beats: Quantitative Assessment,” September 11, 2014.

David Chipman. “MEMO: ATF at a Time of Transition: Underfunded and Unduly Restricted.” Giffords (blog), April 25, 2019.

https://giffords.org/press-release/2019/04/atf-director-announcement-memo/ .

David E. Olson, Don Stemen, Kaitlyn Foust, Cynthia Guzman, Lisa Jacobs, Sophia Juarez,

Holly Michalak, Avery Pankratz, and Amanda Ward. “Sentences Imposed on Those Convicted of Felony Illegal Possession of a Firearm in Illinois.” Center for Criminal Justice Research, Policy, and Practice. Loyola University Chicago, 2021.

Department of Justice Archives. “1117. Restrictions on the Possession of Firearms by Individuals Convicted of a Misdemeanor Crime of Domestic Violence,” February 19, 2015.

https://www.justice.gov/archives/jm/criminal-resource-manual-1117-restrictions-posses sion-firearms-individuals-convicted .

Everytown. “Gun Dealer Reform.” Accessed September 19, 2023.

https://www.everytown.org/solutions/gun-dealer-reform/ .

Everytown. “Lack of Gun Industry Accountability,” 2023.

https://www.everytown.org/issues/lack-of-gun-industry-accountability/ .

Everytown. “Prohibit Assault Weapons.” Accessed September 19, 2023.

https://www.everytown.org/solutions/assault-weapon-ban/ .

Everytown. “Smart Guns and Gun Safety Features.” Accessed August 24, 2023. https://www.everytown.org/solutions/smart-guns-and-gun-safety-requirements/ .

Everytown. “United States v. Rahimi: The Fifth Circuit’s Dangerous and Extreme Decision,” February 8, 2023. https://www.everytown.org/united-states-v-rahimi-the-fifth-circuits-dangerous-and-extr eme-decision/.

Everytown. “VICTORY FOR GUN SAFETY: Following Tireless Advocacy From Moms Demand Action And Students Demand Action, Governor Newsom Signs First-Of-Its-Kind Gun Safety Bill,” July 22, 2022.

https://www.everytown.org/press/victory-for-gun-safety-following-tireless-advocacy-fr om-moms-demand-action-and-students-demand-action-governor-newsom-signs-first-of

-its-kind-gun-safety-bill/ .

Everytown Research & Policy. “Crime Gun Tracing.” Accessed August 24, 2023. https://everytownresearch.org/rankings/law/crime-gun-tracing/ .

Finerty, Margaret. “The Supreme Court’s Bruen Decision and Its Impact: What Comes Next?” New York State Bar Association, August 9, 2022.

https://nysba.org/the-supreme-courts-bruen-decision-and-its-impact-what-comes-next/ .

Fisher, Austin. “Harsher Sentences Do Not Reduce Gun Violence, Research Shows.” Source New Mexico (blog), February 2, 2022.

https://sourcenm.com/2022/02/02/harsher-sentences-do-not-reduce-gun-violence-resear ch-shows/ .

Forman Jr., James. Locking Up Our Own: Crime and Punishment in Black America, n.d.

Giffords. “A Second Chance: The Case for Gun Diversion Programs,” December 7, 2021.

https://giffords.org/lawcenter/report/a-second-chance-the-case-for-gun-diversion-progra ms/ .

Giffords. “Assault Weapons.” Accessed September 19, 2023.

https://giffords.org/gun-laws/policy-areas/hardware-ammunition/assault-weapons/ .

Giffords. Giffords, “Gun Dealers,” accessed August 24, 2023, https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/. Accessed August 24, 2023.

https://giffords.org/gun-laws/policy-areas/gun-sales/gun-dealers/ .

Giffords. Center for American Progress, “Frequently Asked Questions About Gun Industry Immunity,” May 4, 2021, https://www.americanprogress.org/article/frequently-asked-questions-gun-industry-immunity/. Accessed September 19, 2023.

https://giffords.org/gun-laws/policy-areas/other-laws-policies/gun-industry-immunity/.

Giffords. “Tiahrt Amendments.” Accessed August 24, 2023.

https://giffords.org/lawcenter/gun-laws/policy-areas/other-laws-policies/tiahrt-amendme nts/ .

Glenn Thrush, Danny Hakim, and Mike McIntire. “How the A.T.F., Key to Biden’s Gun Plan, Became an N.R.A. ‘Whipping Boy’ - The New York Times,” May 2, 2021.

https://www.nytimes.com/2021/05/02/us/politics/atf-nra-guns.html .

“Gun Industry Immunity in California,” January 5, 2023.

https://giffords.org/lawcenter/state-laws/gun-industry-immunity-in-california/#footnote _0_14451 .

Gwynne Hogan and Suhail Bhat. “NYPD Granting Fewer Gun Permits After Supreme Court Ruled It Had to Grant More, Data Shows.” The City, July 23, 2023.

https://www.thecity.nyc/2023/7/23/23803195/nypd-gun-permit-approvals-bruen-suprem e-court-ghost .

Hemenway, David, Deborah Azrael, and Matthew Miller. “Whose Guns Are Stolen? The Epidemiology of Gun Theft Victims.” Injury Epidemiology 4 (April 10, 2017): 11. https://doi.org/10.1186/s40621-017-0109-8 .

Hill, Michael, Maysoon Khan, and Bobby Caina Calvan. “New York to Restrict Gun Carrying after Supreme Court Ruling.” AP News, September 1, 2022. https://apnews.com/article/us-supreme-court-travel-manhattan-gun-politics-legislature- 507daf2e3b85e72af606b4f44ef2ceab .

Hing, Geoff, and Lakeidra Chavis. “How We Reported on Rising Gun Possession Arrests.” The Marshall Project, May 3, 2023.

https://www.themarshallproject.org/2023/05/03/how-we-reported-on-rising-gun-possess ion-arrests.

John Fritze. “Guns for Domestic Abusers? Skirts at School? A Look at What May Be Next at the Supreme Court.” USA TODAY, June 17, 2023.

https://www.usatoday.com/story/news/politics/2023/06/17/guns-dress-codes-voting-her es-what-may-be-next-for-supreme-court/70321024007/ .

Johns Hopkins Bloomberg School of Public Health. “Opinion: The Fifth Circuit’s Rahimi Decision Protects Abusers’ Access to Guns. The Supreme Court Must Act to Protect Survivors of Domestic Violence.,” March 1, 2023.

https://publichealth.jhu.edu/2023/opinion-the-fifth-circuits-rahimi-decision-protects-ab users-access-to-guns-the-supreme-court-must-act-to-protect-survivors-of-domestic-viol ence .

“Joint Advisory Regarding the Massachusetts Firearms Licensing System After the Supreme

Court’s Decision in New York State Rifle & Pistol Association v. Bruen.”

Massachusetts Attorney General’s Office and the Executive Office of Public Safety and Security, 2022.

Kelly, Raymond W. “Washington’s Secret Gun Files.” The New York Times, June 16, 2007, sec. Opinion. https://www.nytimes.com/2007/06/16/opinion/16kelly.html.

Kohrman, Miles. “States May Have Found a Way Through the Gun Industry’s Liability Shield.” The Trace, August 11, 2022.

https://www.thetrace.org/2022/08/plcaa-california-new-york-allow-lawsuits/ .

Lawlor, Mason. “Maryland Court Follows Supreme Court’s Gun Permit Ruling: ‘Good and Substantial Reason’ Requirement Also Unconstitutional.” Law.com, August 1, 2022. https://www.law.com/2022/08/01/maryland-court-follows-supreme-courts-gun-permit-r uling-good-and-substantial-reason-requirement-also-unconstitutional/ .

Lawrence Hurley. “Supreme Court Considers Recoil from Landmark Gun Rights Ruling,” June 18, 2023.

https://www.nbcnews.com/politics/supreme-court/supreme-court-considers-recoil-land mark-gun-rights-ruling-rcna89261 .

“Legal Alert OAG 2022 02.” California Department of Justice Office of the Attorney General, February 2022.

Los Angeles Times. “Editorial: Newsom Gun Amendment Is a Non-Starter, but It Still Has Value,” July 17, 2023.

https://www.latimes.com/opinion/story/2023-07-17/newsom-gun-amendment-non-start er .

Marcus, Ruth. “A U.S. District Judge Calls the Supreme Court’s Bluff on Guns.” Washington Post , July 8, 2023.

https://www.washingtonpost.com/opinions/2023/07/07/originalism-supreme-court-seco nd-amendment-reeves/ .

Mass.gov. “Extreme Risk Protection Orders.” Accessed September 19, 2023.

https://www.mass.gov/extreme-risk-protection-orders .

McAvoy, Audrey. “Hawaii Allows More Concealed Carry after US Supreme Court Ruling but Bans Guns in Most Places.” AP News, June 3, 2023.

https://apnews.com/article/hawaii-gun-control-law-concealed-carry-permit-72e5ebe107 fdea85319a4552dcb23b97 .

Michela Lowry and Ashmini Kerodal. “Prosecutor-Led Diversion.” Center for Court Innovation, March 2019.

Mitchell Jr., Sharone. “There’s No Second Amendment on the South Side of Chicago,” November 12, 2021.

https://www.thenation.com/article/politics/gun-control-supreme-court/ .

Mitchell, Travis. “The Demographics of Gun Ownership.” Pew Research Center’s Social & Demographic Trends Project (blog), June 22, 2017.

https://www.pewresearch.org/social-trends/2017/06/22/the-demographics-of-gun-owner ship/ .

National League of Cities. “SCOTUS Strikes Down ‘Proper Cause’ Requirement to Carry a Gun in Public,” June 24, 2022. https://www.nlc.org/article/2022/06/24/scotus-strikes-down-proper-cause-requirement-t o-carry-a-gun-in-public/ .

“New Application Instructions · Government Portal.” Accessed August 24, 2023.

https://licensing.nypdonline.org/new-app-instruction/?AspxAutoDetectCookieSupport=

1.

New York Civil Liberties Union. “Stop-and-Frisk Data,” January 2, 2012.

https://www.nyclu.org/en/stop-and-frisk-data .

New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111, 213 L. Ed. 2d 387 (2022)

NY Law. “Article 265 Penal Law Firearms - Dangerous Weapons.” Accessed August 24, 2023. https://ypdcrime.com/penal.law/article265.php .

“NYPD ‘Good Guy’ Note Let Suspect Pack Heat.” Accessed August 24, 2023.

https://nypost.com/2006/05/18/nypd-good-guy-note-let-suspect-pack-heat/ .

Pew Research Center. “Large Majority of Americans Support Raising Minimum Age for Buying Guns to 21,” June 27, 2023. https://www.pewresearch.org/politics/2023/06/28/gun-violence-widely-viewed-as-a-maj or-and-growing-national-problem/pp_2023-06-28_gun-violence_00-04/ .

Pew Research Center. “What the Data Says about Gun Deaths in the U.S.,” April 26, 2023.

https://www.pewresearch.org/short-reads/2023/04/26/what-the-data-says-about-gun-dea ths-in-the-u-s/ .

Picard-Fritsche, Sarah, and Lenore Cerniglia. “Testing a Public Health Approach to Gun Violence.” Center for Court Innovation, 2012.

“Red Flag Law, Ghost Guns for Sale: A New MA Bill Aims to Fix It.” Accessed September 19, 2023.

https://www.bostonglobe.com/2023/07/10/opinion/mass-shootings-gun-safety-legislatio n-ghost-guns-red-flag-law/?utm_source=TMP-Newsletter&utm_campaign=e03e156db 3-EMAIL_CAMPAIGN_2023_07_12_11_02&utm_medium=email&utm_term=0_5e02 cdad9d-e03e156db3-%5BLIST_EMAIL_ID%5D .

Reeves, Carlton. United States of America V. Jessie Bullock, 3:18-cr-00165-CWR-FKB § (2023).

“Report of Active Firearms Licenses.” Bureau of Alcohol, Tobacco, Firearms and Explosives, January 10, 2020.

Reuters. “DOJ Asks Supreme Court to Uphold Domestic Violence Gun Law.” NBC News, March 18, 2023. https://www.nbcnews.com/politics/supreme-court/justice-department-asks-supreme-cou rt-uphold-domestic-violence-gun-law-rcna75606 .

“Review of ATF’s Federal Firearms Licensee Inspection Program.” U.S. Department of Justice, April 2013.

Samarth, Avinash Nitin, and Meghna Philip. “Brief of the Black Attorneys of Legal Aid, the Bronx Defenders, Brooklyn Defender Services, Et Al. As Amici Curiae in Support of Petitioners,” n.d.

Sarah Bedford. “Democrats Call for More Gun Laws despite Not Enforcing the Ones They Have.” Washington Examiner, April 20, 2023.

https://www.washingtonexaminer.com/restoring-america/fairness-justice/democrats-wa nt-more-gun-laws-dont-enforce-ones-they-have .

Sen. Craig, Larry E. [R-ID. “Text - S.397 - 109th Congress (2005-2006): Protection of Lawful Commerce in Arms Act.” Legislation, October 26, 2005. 2005-02-16. http://www.congress.gov/bill/109th-congress/senate-bill/397/text .

“Sen. Menendez, Rep. Lee Reintroduce Bicameral Bill to End NRA-Backed Ban on Preservation, Disclosure of Gun Records.” Accessed August 24, 2023. https://www.menendez.senate.gov/newsroom/press/sen-menendez-rep-lee-reintroduce-b icameral-bill-to-end-nra-backed-ban-on-preservation-disclosure-of-gun-records .

The Bipartisan Safer Communities Act, 1 Year Later. (2023, August 10). Center for American Progress. https://www.americanprogress.org/article/the-bipartisan-safer-communities-act-1-year-later/

The Brooklyn District Attorney’s Office. “Youth Diversion,” n.d.

“The Economic Cost of Gun Violence,” July 19, 2022.

https://everytownresearch.org/report/the-economic-cost-of-gun-violence/.

“The Evidence of Effectiveness: Cure Violence.” Cure Violence Global, August 2022.

United States Attorney’s Office Northern District of California. “Northern District of California | Operation Ceasefire and the Safe Community Partnership,” November 18, 2014.

https://www.justice.gov/usao-ndca/operation-ceasefire-and-safe-community-partnership

Young Activists Call for Reforms to Combat Gun Violence | C-SPAN.org. (n.d.). Retrieved October 24, 2023, from https://www.c-span.org/video/?c5074816/young-activists-call-reforms-combat-gun-violence