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102 J. Crim. L. & Criminology 471 (2012)
The Responsible Gun Ownership Ordinance and Novel Textual Questions about the Second Amendment

handle is hein.journals/jclc102 and id is 491 raw text is: 0091-4169/12/10202-0471 THE JOURNAL OF CRIMINAL LAW & CRIMINOLOGY Vol. 102, No. 2 Copyright @ 2012 by Northwestern University School of Law Printed in US.A. THE RESPONSIBLE GUN OWNERSHIP ORDINANCE AND NOVEL TEXTUAL QUESTIONS ABOUT THE SECOND AMENDMENT Owen McGovern* Although gun ownership is a fundamental right under the Second Amendment of the Constitution,' it is subject to reasonable restrictions.2 The City of Chicago's most recent attempt to define the contours of those restrictions raises serious textual questions about the meaning of the Second Amendment. This Comment will evaluate various provisions of Chicago's new firearm ordinance and conclude (1) that it is likely unconstitutional and (2) that future gun-control regulations will only be upheld if they respect the full understanding of the contours of the Second Amendment adopted in Heller, rather than merely satisfying its narrow holding. I. INTRODUCTION In the wake of District of Columbia v. Heller3 and McDonald v. City of Chicago,4 the City of Chicago promptly amended the Responsible Gun Ownership Ordinance (the Ordinance) to further its interest in protecting the public welfare and safety.5 The Ordinance immediately generated federal J.D., Northwestern University School of Law, 2012. I McDonald v. City of Chicago, 130 S. Ct. 3020, 3042 (2010). 2 District of Columbia v. Heller, 554 U.S. 570, 626-27 (2008) (listing reasonable restrictions, such as longstanding prohibitions on the possession of firearms by felons and the mentally ill, or laws forbidding the carrying of firearms in sensitive places such as schools and government buildings, or laws imposing conditions and qualifications on the commercial sale of arms). 554 U.S. 570. 4 130 S. Ct. 3020. Chi., Ill., Responsible Gun Ownership Ordinance (July 2, 2010) (codified in scattered sections of CHI., ILL., MUN. CODE (2010)). 471

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