Second Circuit Upholds Sullivan Law

Via Jacob, the decision can be found here. The decision will be appealed. In the decision they kind of dabble in the history and tradition argument, without really going into serious analysis, then you get this:

But Plaintiffs’ contention that the proper cause requirement grants licensing officials unbridled discretion is something of a red herring. Plaintiffs admit that there is an established standard for determining whether an applicant has demonstrated proper cause. The proper cause requirement has existed in New York since 1913 and is defined by binding judicial precedent as “a special need for self-protection distinguishable from that of the general community or of persons engaged in the same profession.”

Plaintiffs’ complaint is not that the proper cause requirement is standardless; rather, they simply do not like the standard—that licenses are limited to those with a special need for self-protection. This is not an argument that licensing officials have unbridled discretion in granting full-carry permits. In fact, the State Defendants’ determinations that Plaintiffs do not have a special need for self-protection are unchallenged. Rather, Plaintiffs question New York’s ability to limit handgun possession to those demonstrating a threat to their safety. This is precisely the type of argument that should be addressed by examining the purpose and impact of the law in light of the Plaintiffs’ Second Amendment right.

Plaintiffs’ attempts to equate this case with Heller or to draw analogies to First Amendment concerns come up short.

They go on to conclude the core right is a right in the home, and make analogies to privacy rights, and speak of the home as having high constitutional protections relative to public places, even going so far as to recall rulings that allow obscenity to be possessed in homes, but banned in public.

They then go the traditional route for the lower courts, which is to apply intermediate scrutiny, which of course means the statute in question survives. Can you think of any case where a gun control statute was tossed using intermediate scrutiny? I can think of Ezell, but that was heightened-almost-scrict scrutiny. It seems the courts in these cases believe that if they just rename rational basis to be intermediate scrutiny, using rational basis review somehow becomes OK, as long as you don’t call it that.

Either the lower courts are in for an epic smack down after all these carry cases play out in the lower courts, or taking this issue into the courts is going to turn out to be an epic mistake, and we’re going to end up with a Second Amendment right that is a mish-mash of the worst things the state courts have already done to it. I am sincerely hoping the former is the case.

Failing to Understand Rights

And this from a Laywer. I’d never hire this guy:

Perhaps it is time that the Florida Department of Law Enforcement takes away the responsibility of overseeing concealed weapons from the Department of Agriculture? Just because having a gun in Florida is a constitutionally protected right does not mean it should be so cheap and so easy.

Shouldn’t exercising a right be, by the very concept of a right, “cheap” and “easy?” Does our HuffPo lawyer columnist believe that one can tax speech? What about the right to marry? The Supreme Court of the United State has said “no,” that free speech may not be taxes. And at least one state has said no to marriage. How can a right be constitutionally protected if the citizen may be taxed and frustrated from its exercise?

Mr. Aronfeld, if you don’t like the idea of keeping and bearing arms being a right, then just say so. Suggesting it’s some special right that deserves no real protection is intellectually dishonest and unworthy of a legal mind.

Home Defense: How Not to Do It

Hat tip to Joan Peterson for this story on a guy who shot two burglars execution style, and is being charged with murder. It is not often I agree with Joan, but I do agree that the homeowner’s behavior here was criminal and reprehensible. But I do want to explain the law here, especially as it relates to Castle Doctrine, so that we may dispel some common myths. First, from the story:

Brady fell down the stairs and was looking up at Smith when the homeowner shot him in the face.

“I want him dead,” Smith explained to the investigator for the additional shot.

Smith put Brady’s body on a tarp and dragged him to an office workshop.

A few minutes later, Smith heard footsteps above him. As in Brady’s case, Kifer too started down the stairs and was shot by Smith by the time he saw her hips, sending her tumbling down the stairs.

Smith attempted to shoot her again, but his rifle jammed, prompting Kifer to laugh.

Upset, Smith, pulled out a revolver he had on him and shot her “more times than I needed to” in the chest, he said.

Smith dragged Kifer next to Brady as she gasped for her life. He pressed the revolver’s barrel under her chin and pulled the trigger in what he described as a “good, clean finishing shot” that was meant to end her suffering.

Smith acknowledged leaving the bodies in his home overnight before calling a neighbor to ask about a lawyer and to request that authorities be notified.

In nearly all 50 states, including Minnesota, the mere use of deadly force in the circumstance of someone feloniously entering your home is, generally speaking, legitimate self-defense. In many states, forced entry into an occupied dwelling is considered prima facie evidence that a deadly threat exists. Minnesota, following traditional common law, allows for deadly force to be used to prevent the commission of a felony, though in MN limited to one’s place of abode, and burglary is a felony in Minnesota. Minnesota law states:

609.065 JUSTIFIABLE TAKING OF LIFE.

The intentional taking of the life of another is not authorized by section 609.06, except when necessary in resisting or preventing an offense which the actor reasonably believes exposes the actor or another to great bodily harm or death, or preventing the commission of a felony in the actor’s place of abode.

Regardless of whether castle doctrine has passed in Minnesota or not, there is already an absolute unqualified right (qualified by a duty to retreat in some circumstances in the home imposed by judicial fiat) to respond to burglars invading an occupied home in Minnesota with deadly force, but only if the purpose of such force is to prevent the continuing felony, or to protect life and limb. Murder is never lawful, and Minnesota, like most states, defines (in this case 2nd degree) murder as when someone “causes the death of a human being with intent to effect the death of that person or another, but without premeditation,” (emphasis mine). As soon as you say something like this to the police:

“I want him dead,” Smith explained to the investigator for the additional shot.

[…]

Upset, Smith, pulled out a revolver he had on him and shot her “more times than I needed to” in the chest, he said.

Smith dragged Kifer next to Brady as she gasped for her life. He pressed the revolver’s barrel under her chin and pulled the trigger in what he described as a “good, clean finishing shot” that was meant to end her suffering.

That’s the intentional infliction of death, which is murder. The intent in self-defense is never to inflict death, but to stop the attack, or in the case of Minnesota law, to prevent to commission of a felony. Once they are down, they are no longer a threat and no longer committing a felony. To take a “finishing shot,” becomes murder. This is regardless of the Castle Doctrine law.

I say this because our opponents characterization of this law as “shoot first,” and “license to kill,” creates the very real danger, when combined with an ignorant and unquestioning media willing to repeat their rhetoric, that some fool or whack job may actually believe it. This man confessed his crime willingly to the police. Why would he do that if he did not believe he was in the right? Let us not continue to peddle the myths about deadly force laws. Murder is always illegal.

A Review of the Red Dawn Remake

I have not seen it, but Tactical Tupperware has, and liked it, suggesting it had better production values and was more polished than the original. I had not planned to go see it, but considering the movie is upsetting the right kind of people, perhaps I need to get to the theaters and support this kind of film.

Gun Control: It’s Obsolete

You can make an AK-47 receiver from a shovel with common household tools. I think I’ve seen Kyber pass AKs with shovel handles as a stock, which makes me wonder if they use the same technique to make their AK receivers.

And it’s not just gun control that’s a ridiculous, fruitless endeavor. Explosives regulations are just about as bad, given that you can make boomerite from ice packs.

Dangerous insurrectionist …

or nerd?* You decide.

* I should note that I am definitely not one to be throwing stones from this particular glass house, but I thought it was funny when you consider what our opponents paint us as being. I can imagine them scratching their heads wondering if those D&D modules come in handy at the local militia meetings.

Screwed Again

Clayton Cramer notes:

Which means a lot of Obama voters — people that bought into Obama’s “soak the rich” rhetoric — who have been able to deduct the first $2,500 of student loan interest from their federal income taxes — are going to lose that deduction if they are more than five years into their loans.

Since they introduced this deduction, I’ve always been above the income cap for being able to take it. With a sharp income reduction in this era of hope and change, this year I’d probably be able to take it… and now it may go away.

I think I’m part of the generation that’s always going to find themselves paying for all this wonderful government, but never actually benefitting from any of it.