Ammoland Inc. Posted on August 14, 2026 by AmmoLand Editor Duncan Johnson
Chicago required residents to complete live-fire training before legally possessing a firearm while simultaneously banning public shooting ranges within city limits. iStock-2217328010
More than a decade before the Supreme Court struck down Hawaii’s attempt to make lawful carry practically impossible in Wolford v. Lopez, Chicago tried the same basic trick with firearm ownership.
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The city required residents to complete live-fire training before they could obtain the permit necessary to possess a firearm. Chicago then banned every public firing range within city limits.
You had to train before you could lawfully own a gun, but the city prohibited you from training. That was not public-safety regulation. It was a handgun ban rebuilt with paperwork.
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The Seventh Circuit saw through it in Ezell v. City of Chicago, 651 F.3d 684 (7th Cir. 2011).
Chicago’s Post-McDonald End Run
For nearly three decades, Chicago effectively prohibited ordinary citizens from possessing handguns. The Supreme Court put an end to that in McDonald v. City of Chicago, holding that the Second Amendment applies to state and local governments through the Fourteenth Amendment.
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Chicago’s political class did not accept that decision gracefully.
Just four days after McDonald, the City Council adopted its so-called Responsible Gun Owners Ordinance. The sprawling law imposed permits, registration, fees and severe restrictions on where firearms could be possessed.
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To obtain a Chicago Firearm Permit, an applicant had to complete a certified safety course that included one hour of range training. At the same time, the ordinance prohibited all shooting galleries and firing ranges in the city. Government and certain private-security ranges remained available, but ordinary Chicago residents could not use them.
Rhonda Ezell and two other Chicago residents challenged the scheme alongside Action Target, the Second Amendment Foundation and the Illinois State Rifle Association. After the district court refused to issue a preliminary injunction, the plaintiffs appealed.
The Seventh Circuit reversed.
The Right to Keep Arms Includes Learning to Use Them
Judge Diane Sykes explained that the right to possess a firearm for self-defense necessarily carries with it the right to acquire and maintain proficiency.
“The core right wouldn’t mean much without the training and practice that make it effective,” the court observed.
That conclusion was not manufactured from a judge’s personal views about guns. The court looked to the original meaning of the Second Amendment and the historical record surrounding both 1791 and the ratification of the Fourteenth Amendment in 1868.
The opinion cited Thomas Cooley’s influential 1868 constitutional treatise, which explained that bearing arms implied more than merely keeping them. It included learning to handle and use them and meeting for voluntary discipline in arms.
Chicago pointed to historical laws restricting the discharge of firearms in populated areas. But those laws did not establish a tradition of prohibiting controlled target practice. Many contained exceptions for shooting at designated targets or allowed firearm practice with permission from local authorities. Those were regulations of unsafe discharge, not blanket bans on training.
The city could identify only a couple of broad historical prohibitions unrelated to fire prevention. A few isolated laws could not overcome the larger historical record, particularly when other cities expressly accommodated target shooting.
Speculation Is Not Evidence
Chicago claimed firing ranges might produce accidents, attract thieves or expose shooters to lead. The city, however, presented no meaningful data or expert evidence showing that a complete ban was necessary.
The Seventh Circuit noted that ordinary zoning, construction and safety regulations could address legitimate concerns. Properly designed indoor ranges were already operating safely near homes, schools, churches and stores—including ranges used by Chicago law enforcement.
The city’s lead-contamination argument became so strained that the litigation wandered into a discussion about whether portable toilets supplied enough water for shooters to wash their hands. The majority wrote that raising the issue as justification for banning every range “suggests pretext.”
Judge Ilana Rovner concurred in the judgment, calling Chicago’s ordinance “too clever by half” and “a thumbing of the municipal nose at the Supreme Court.”
The Seventh Circuit ordered the district court to enjoin the range ban and related provisions that prevented residents from possessing or transporting firearms for training. Chicago remained free to impose historically supportable safety rules. It could not use those rules to exclude ranges from the entire city.
When Chicago responded with restrictive zoning, distancing and age requirements, the Seventh Circuit struck those down in 2017 as well. The combined zoning rules left only 2.2% of the city theoretically available for ranges, and not one public range had opened. The court again rejected Chicago’s speculative safety arguments.
Ezell in 2026
Part of Ezell’s legal framework has since been overtaken by N.Y. State Rifle & Pistol Association v. Bruen. The Ezell majority applied a demanding form of heightened scrutiny after completing its historical analysis. Bruen rejected that second stage of judicial interest balancing.
Today, once the Second Amendment’s text covers a person’s conduct, the government must prove that its restriction is consistent with the nation’s historical tradition of firearm regulation. That makes Ezell’s historical analysis more important.
The modern parallel is unmistakable. After losing in Bruen, Hawaii enacted a default rule prohibiting carry on private property open to the public without express permission. In June 2026, the Supreme Court struck that rule in Wolford v. Lopez, recognizing that it hobbled the right to carry during ordinary daily life.
Chicago did the same thing after McDonald: replace the ban the Court rejected with a regulatory scheme engineered to reach the same result.
The lesson from Ezell remains simple. Government cannot demand that citizens satisfy a condition, outlaw every practical means of satisfying it and then pretend the right still exists.
The Second Amendment is not a zoning suggestion or a privilege available only when city officials leave an approved location open. It protects the right to keep and bear arms—and a right that cannot be learned, practiced or meaningfully exercised is no right at all.
