## Facts

- After Chicago’s handgun ban was invalidated, the City required at least one hour of live-fire range training as a prerequisite for lawful handgun possession.
- The City simultaneously adopted a regulatory scheme governing where and how shooting ranges could operate.
- The challenged provisions included: (a) allowing ranges only as “special uses” in manufacturing districts, (b) requiring ranges to be at least 100 feet from another range and 500 feet from residences and other listed sensitive uses, and (c) barring anyone under 18 from entering any range even for supervised training.
- The combined siting limits left only about 2.2% of the City’s acreage theoretically available for range locations, and no range had opened in Chicago under the ordinance.
- The City justified the restrictions on public health and safety grounds (e.g., lead, fire, theft, crime) but provided limited empirical support.
- The district court permanently enjoined the manufacturing-district restriction but upheld the distancing and under-18 provisions; both sides appealed.

## Issues

1. Whether restricting ranges to special uses in manufacturing districts unconstitutionally burdens Second Amendment rights related to firearms training.
2. Whether the 100-foot/500-foot distancing requirements are consistent with the Second Amendment.
3. Whether banning persons under 18 from entering ranges, including for supervised instruction, violates the Second Amendment.
4. What level of scrutiny applies to regulations that substantially burden access to firing-range training tied to armed self-defense.

## Decision

- Affirmed the permanent injunction against the manufacturing-district “special use” restriction.
- Reversed the judgment upholding the distancing requirements and held them unconstitutional.
- Reversed the judgment upholding the under-18 entry ban and held it unconstitutional.
- Remanded for further proceedings consistent with the opinion.

## Legal Principles

- Range training and target practice are protected Second Amendment activities closely connected to the core right of armed self-defense.
- Courts apply a sliding-scale form of heightened scrutiny: the more severe the burden on a core-related Second Amendment interest, the stronger the required public-interest justification and the tighter the fit between means and ends.
- Governments must support public-safety justifications with evidence; speculative or generalized assertions are insufficient when regulations substantially impair protected activity.
- Second Amendment analysis considers the real-world operation of the regulatory scheme, including how multiple provisions combine to restrict access.

## Conclusion

The Seventh Circuit invalidated Chicago’s principal range-location restrictions and its categorical ban on minors’ range entry, holding that measures that effectively prevent meaningful access to range training impose a severe burden on protected Second Amendment activity and require strong, evidence-based justification and close tailoring.


Ezell v. City of Chicago, 846 F.3d 888 (7th Cir. 2017)