Explore The NRA Universe Of Websites

APPEARS IN News

“Sensitive Places” Embolden Criminals and Threaten the Law-abiding

Monday, September 15, 2025

“Sensitive Places” Embolden Criminals and Threaten the Law-abiding

A beyond horrific murder flashed before our eyes in recent weeks, and a nation collectively mourned Iryna Zarutska after the sickening attack that took her life on a public train in Charlotte, North Carolina. It was yet another stark reminder that evil strikes quickly, and it can happen at any time, in any place (particularly when, as in the case of the Charlotte suspect, the legal system appears incapable or unwilling to incapacitate repeat offenders).

Because of that very fact, the law-abiding citizens who choose to carry firearms for self-defense in public are again left frustrated by imaginary boundaries that continue to limit their ability to defend themselves. Firearm prohibitionists argue, “The presence of guns make places more dangerous.” Wrong. Bad people make places more dangerous. And some places may be more likely to attract or accommodate bad people than others, not the least of which are public transportation facilities, including subway stations, bus stops, etc.

If citizens cannot count on courts or policymakers to prioritize their safety, they are left to their own devices when situational awareness is simply not enough. Rules that restrict an individual’s right to bear arms for self-defense advantage criminals, and as public officials dither, lives are in danger.

NRA has often reported on the safety ills of the NYC subway system, even documenting that it was deemed contractually too dangerous for former New York Giants Quarterback, Eli Manning.

Recall that in the landmark United States Supreme Court decision Heller v. District of Columbia, it was noted that the Second Amendment’s protection of an individual right to keep and bear arms did not cast doubt on the validity of “laws forbidding the carrying of firearms in sensitive places such as schools and government buildings.” However, Justice Clarence Thomas in New York State Rifle & Pistol Association v. Bruen later warned that the expansion of “sensitive places” beyond historical precedents is unconstitutional:

[E]xpanding the category of “sensitive places” simply to all places of public congregation that are not isolated from law enforcement defines the category of “sensitive places” far too broadly. [New York’s] argument would in effect exempt cities from the Second Amendment and would eviscerate the general right to publicly carry arms for self-defense...

Justice Thomas’s warning continues to be ignored.

Just last week, a three-judge panel of the U.S. Court of Appeals for the Seventh Circuit ruled in Schoenthal v. Raoul, a case out of Chicago in which NRA-ILA filed an amicus brief, that broad limits on self-defense can continue.

The Chicago Transit Authority and Illinois state law prohibit carrying firearms on public transit. The Seventh Circuit, in reversing an earlier district court ruling, held that the Second Amendment “does not bar the people’s representatives from enacting laws-consistent with our nation’s historical tradition of regulation—that ensure public transportation systems remain free from accessible firearms.”

Not only is carrying firearms in public for self-defense clearly covered by the plain text of the Second Amendment, there is no historical tradition of banning firearms on public transit, even though forms of it existed in the Founding era. The Seventh Circuit essentially admitted as much, when it asserted: “We are in the project of comparing regulations, not places.” Then, “reasoning” from mid to late 19th Century bans on places like “ball[s] and fandango[es],” the court came up with a broad rule that firearm prohibitions in “in crowded and confined places” are presumptively permissible.

This tendency of courts to stretch historical analogies on “sensitive places” far past their breaking point is leaving far too many people in vulnerable locations to be victimized.  Judge Kolar writes that the “sensitive places doctrine tells us that the appropriate balance allows for temporary restrictions in scattered discrete places where the risk is simply different…”  The risk on public transit is indeed different. These places are inherently more dangerous and call for even more accommodation for self-defense rights. No one in the Founding era thought the solution to robberies of stage coaches and trains was to ban passengers from carrying guns.

Judge Kolar is concerned about the people’s representatives being able to ensure “public transportation systems remaining free from accessible firearms,” yet the people’s representatives are doing precious little to ensure the transportation systems remain free of violent criminals.

Public transportation in Chicago, in fact, is about as “insensitive” a place as exists in public life. According to a 2024 study done by the Illinois Policy Institute, over 1 in every 100,000 Chicago Transit Authority rides resulted in a crime. That’s about 1 crime every 3 hours, considering 765,566 rides per weekday on average. About 45% of all crimes reported at CTA stations result in an arrest, according to analysis of city data, meaning criminals have a better than even chance of getting away with their predations. And those are just the crimes that get reported. Many more do not, as few victims expect justice.

Daily there are headlines nationwide featuring the safety hazards of public transit. Attacks are often random. Carrying a gun on Chicago public transportation is illegal, but so are assaults, thefts, and harassment. Gun owners are obeying the law, but Chicago criminals are not.  

Violence prevention and mental healthcare sometimes pose complex questions, but the self-defense part of the equation is simple: the need can arise wherever a person happens to be. Rulings like the one from the Seventh Circuit demonstrate the continued work needed to fend off ever-expanding “gun-free zones” that, like the may-issue permitting condemned by the Supreme Court, make carry the exception, rather than the rule. 

Simply put, “sensitive places” show an insensitivity to the Second Amendment and the lives of the people it is meant to protect.

TRENDING NOW
Connecticut’s “Convertible Pistol” Ban Picks up Where California’s Overreach Left Off

News  

Monday, February 23, 2026

Connecticut’s “Convertible Pistol” Ban Picks up Where California’s Overreach Left Off

What the Second Amendment community has long known has become increasingly difficult for gun grabbers to deny: no handgun is safe from the prohibitionist agenda.

Virginia: Gun Bill Updates As Crossover Deadline Arrives

Tuesday, February 17, 2026

Virginia: Gun Bill Updates As Crossover Deadline Arrives

Today, February 17th is the legislative crossover deadline in Virginia, and any bills that have not left their chamber of origin by the end of the day are considered dead for the session.

Minnesota: Gun Control Bills Stall in Committee

Wednesday, February 25, 2026

Minnesota: Gun Control Bills Stall in Committee

Following committee votes on Tuesday, February 24th, and Wednesday, February 25th, many of the most egregious gun controls bills in the legislature have stalled and may not receive further action this session.

Virginia Gun Owners Face Magazine Confiscation!

Monday, February 2, 2026

Virginia Gun Owners Face Magazine Confiscation!

Astute Virginia gun owners anticipated terrible gun control legislation from the 2026 General Assembly. Still, some may be shocked to learn that anti-rights zealots in the Virginia Senate have advanced a bill to CONFISCATE standard capacity firearm ...

NRA Announces Third Lawsuit Challenging the National Firearms Act

Thursday, February 26, 2026

NRA Announces Third Lawsuit Challenging the National Firearms Act

Today, the National Rifle Association announced the filing of a third lawsuit challenging the constitutionality of the National Firearms Act of 1934 (NFA). The case, Roberts v. ATF, was filed in the U.S. District Court for ...

Firearms Industry “Responsible Controls” Legislation is an Existential Threat to Gun Owners

News  

Monday, February 23, 2026

Firearms Industry “Responsible Controls” Legislation is an Existential Threat to Gun Owners

Anti-gun activists think they have figured out a way around the Second Amendment, democratic accountability, and the federal Protection of Lawful Commerce in Arms Act (PLCAA) to impose a limitless raft of gun control on ...

Minnesota: Hearing on Semi-Auto and Magazine Bans Next Week

Friday, February 20, 2026

Minnesota: Hearing on Semi-Auto and Magazine Bans Next Week

On Tuesday, February 24th, the House Public Safety Finance and Policy committee will hold a hearing on two all-encompassing ban bills, House File 3433 and House File 3402

Washington: Bill Removing Fee Cap on Firearm Background Checks Advances AFTER Crossover Deadline

Wednesday, February 25, 2026

Washington: Bill Removing Fee Cap on Firearm Background Checks Advances AFTER Crossover Deadline

On Tuesday night, the Washington legislature suspended the rules to move House Bill 2521 and voted to pass it off the House Floor AFTER the legislative crossover deadline of February 17th.

Oregon: Ballot Measure 114 Override Bill Passes House

Wednesday, February 25, 2026

Oregon: Ballot Measure 114 Override Bill Passes House

This afternoon, House Bill 4145, the Ballot Measure 114 override bill, passed out of the House and will be transmitted to the Senate for further consideration.

Virginia: Multiple Gun Control Bills Advance in Senate

Tuesday, January 27, 2026

Virginia: Multiple Gun Control Bills Advance in Senate

On Monday, January 26th, the Senate Courts of Justice Committee advanced a slate of gun control bills targeting semi-automatic firearms, standard capacity magazines, carry rights, home storage, and more.

MORE TRENDING +
LESS TRENDING -

More Like This From Around The NRA

NRA ILA

Established in 1975, the Institute for Legislative Action (ILA) is the "lobbying" arm of the National Rifle Association of America. ILA is responsible for preserving the right of all law-abiding individuals in the legislative, political, and legal arenas, to purchase, possess and use firearms for legitimate purposes as guaranteed by the Second Amendment to the U.S. Constitution.