McDonald case - coming amicus briefs on behalf of Chicago

[Thirdpower]

Read it through this morning. Like Todd, the first thing that jumped out at me was the feeling that most of what they;re doing is trying to re-argue Heller and pray that Slaughterhouse doesn't get overturned.

 

Are we really so far ahead that this is the best they can do?

[drdoom]

"4. Finally, the treatment of firearms rights in other

countries—especially countries that share our Anglo-

American heritage—supports the conclusion that the

Second Amendment right is not implicit in the

concept of ordered liberty. The legal systems of

England, Canada, and Australia each have their

roots in the same English law as does this country,

and each should be seen as a country in which

“ordered liberty” is valued. Yet each of them imposes

stringent regulations on firearms that would be

impermissible or at least suspect under Second

Amendment standards.

For example, England itself—from whose arms

right ours is derived—bans handguns. See Firearms

(Amendment) Act, 1997, c. 5, § 1 (Eng.); Firearms

(Amendment) (No. 2) Act, 1997, c. 64, § 1 (Eng.). In

addition, applications to possess other firearms for

protection “should be refused on the grounds that

firearms are not an acceptable means of protection

in Great Britain.” Home Office, Firearms Law

Guidance to the Police (2002) (located at http://police.

homeoffice.gov.uk/publications/operational-policing/HOFirearms-

Guidance2835.pdf?view=Binary), ch. 13.72.

Arms possession is generally limited to “good reasons”

such as hunting, target shooting, pest control,

slaughtering, and collecting, and requires extensive

governmental investigation and verification. See

generally id. ch. 13.

Canada, too, imposes stringent regulations on the

possession and storage of handguns. While handguns

are available for target practice, competitions, and

collecting activities, they may be possessed for selfdefense

only upon a showing that the gun is needed

for self-protection. See Firearms Act, S.C. 1995, c. 39,

§§ 4, 28, 54. Approval to carry a handgun requires a

22

showing that someone’s life “is in imminent danger”

and that “police protection is not sufficient.” Authorizations

to Carry Restricted Firearms and Certain

Handgun Regulations, SOR/98-207, § 2. See also

Firearms Act, § 20. Moreover, a handgun must be

stored unloaded and either (i) rendered inoperable by

a locking device and stored in a locked case or room

or (ii) locked in a specially constructed vault or room.

See Storage, Display, Transportation and Handling of

Firearms by Individuals Regulations, SOR/98-209,

§§ 6, 7. Australia too has similar, very stringent

regulations. Although it permits possession of handguns,

it does so only for a limited number of reasons,

not including self-defense. See Australian Police

Ministers’ Council, Special Firearms Meeting,

Genuine Reason for Owning, Possessing or Using

a Firearm Resolution (1996) (available at http://

www.austlii.edu.au/au/other/apmc/#RTFToC3)."

 

What relivance does this have Chicago? The right to arms in England, along with many provisions of the Magna Carta, were repealed during the reign of Queen Victoria. If they are going to mention these, perhaps they should explain the long-forgotten struggle of the Charterists and Anti-Charterists (those who struggled to keep the Magna Carta law of the land as opposed to those who wanted it gone).

[05FLHT]

drdoom, I read that part and also wondered why they would bother to mention that considering England, Canada and Australia do not have the Second Amendment.

 

I found this on http://joshblackman.com/blog/. It is, what I think, a pretty good break down of Chicago's brief.

 

Instant Analysis of the Respondent Brief of the City of Chicago in McDonald v. Chicago

DEC 31ST

Posted by Josh Blackman in 2nd Amendment 13 comments

Here is my Instant Analysis of the city of Chicago’s Respondent Brief in McDonald v. Chicago. You can download the brief here. For my thoughts on McDonald and Privileges or Immunities, see my article, co-authored with Ilya Shapiro, titled Keeping Pandora’s Box Sealed: Privileges or Immunities, The Constitution in 2020, and Properly Extending the Right to Keep and Bear Arms to the States, forthcoming in the Georgetown Journal of Law & Public Policy.

 

In short, Chicago argues:

I. THE DUE PROCESS CLAUSE DOES NOT INCORPORATE THE SECOND AMENDMENT RIGHT TO KEEP AND BEAR ARMS.

 

A Provision Of The Bill Of Rights Applies To The States Under The Due Process Clause If It Is “Implicit In The Concept Of Ordered Liberty.” Regulation Or Prohibition Of Fire- arms, Particularly Handguns, May Reasonably Be Thought To Preserve, Not Intrude On, Ordered Liberty

 

II. THE COURT SHOULD ADHERE TO PRECEDENT REJECTING INCORPO- RATION UNDER THE PRIVILEGES OR IMMUNITIES CLAUSE

 

Even If Viewed De Novo, The Histor- ical Record Provides No Basis For Imposing The Second Amendment On The States. Petitioners Fail To Carry Their Bur- den Of Showing That This Court Should Abandon Its Traditional Due Process Approach To Incorporation

I have only given this brief a cursory glance, but a few things jump out at me.

 

1. First, the Respondents take on the “implicit in the concept of ordered liberty” incorporation test is a new one for me.

 

Bill of Rights provisions are incorporated into the Due Process Clause only if they are implicit in the concept of ordered liberty . . . Thus, Chicago and Oak Park may reasonably conclude that in their communities, handgun bans or other stringent regulations are the most effective means to reduce fear, violence, injury, and death, thereby enhancing, not detracting from, a system of ordered liberty

 

Because handguns are so well adapted for the commission of crimes and the infliction of injury and death, stringent handgun regulations, including prohibitions, can be reasonably thought to create the conditions necessary to foster ordered liberty, rather than detracting from it.

 

Because guns lead to violence, in order to promote liberty, the states must be able to ban guns. To eliminate the states ability to ban gun actually decreases liberty. This is a very curious definition of liberty. Under this interpretation, in order for some people to be free from violence, others need to be forcibly disarmed and denied of their liberty.

 

2. Second, the Respondents fall into the trap of considering originalism at the wrong time. When considering the right to keep and bear arms as applied to the states, the key year is 1868, and not 1791. Yet, they rehash the debates from Heller about the right during the time of the Revolution. While they discuss the ratification of the 14th amendment, this discussion of the ratification of the 2nd amendment has limited utility.

 

Second Amendment, that history does not support incorporation. Although a right to fire- arms for personal use was recognized in a variety of sources of law that pre-existed the Constitution, District of Columbia v. Heller, 128 S. Ct. 2783 (2008), makes clear that it was not included in the Bill of Rights for its own sake or to protect it against the political process; rather, it was codified to protect the militia by eliminating the threat that the federal government would take away the arms necessary for militia service. Nothing in the congressional debate over the Amendment suggests any view that a private arms right unconnected to preservation of the militia was thought implicit in the concept of ordered liberty. The scope of the Second Amendment right— weapons in common use—also reflects its purpose of protecting the militia, rather than an individual right related to self-defense, since the Second Amendment protects weapons regardless of whether they are useful for self-defense.

 

The congressional debate surrounding Madison’s proposal for the Second Amendment tends to confirm that conclusion. If the Second Amendment right were thought essential to protect a non-militia-related personal liberty from governmental intrusion and from the political process, some trace of that belief would likely have surfaced. But nothing in the con- gressional debate over Madison’s proposal for the Second Amendment suggests any view that a private arms right unconnected to preservation of the militia was essential. See The Complete Bill of Rights: The Drafts, Debates, Sources, and Origins, 169-76, 185-91 (Cogan ed. 1997); Jack Rakove, The Second Amend- ment: The Highest Stage of Originalism, 76 Chi.-Kent L. Rev. 103, 127-28 (2000).20

3. Third, in their treatment of Slaughter-House, the Brief omits any reference to the near-universal academic consensus that it was wrongly decided. The best argument they make finds that the Justices on the Slaughter-House court were 20 years removed from the 14th amendment, and were in the best position to understand the original meaning of the P/I clause. This is mildly persuasive, but I would have preferred to see substantive responses to the literature showing how Slaughter-House was correct.

 

4. Fourth, their reliance on Federalism to justify the ban is questionable. While the states can, and should be, laboratories to experiment, legislatures are still bound by the Constitution as a floor.

 

The genius of our federal system ordinarily leaves this type of social problem to be worked out by state and local governments, without a nationally imposed solution excluding one choice or the other. See United States v. Morrison, 529 U.S. 598, 618 (2000) (“[W]e can think of no better example of the police power, which the Founders denied the National Government and reposed in the States, than the suppression of violent crime and vindication of its victims.”).

A state cannot act as a laboratory by infringing a person’s freedom from unreasonable search and seizure because the person is dangerous. No more should a state be able to deny a person’s right to self-defense because it could be “dangerous.” The Federalism argument just seems rather weak.

 

5. Fifth, the arguments for stare decisis should have been expected. Yet, the Petitioners do not ask for the Court to displace the modern substantive due process jurisprudence, contrary to the Respondent’s assertions.

 

The current rule is workable and venera- ble; significant reliance interests are in place; and there is nothing petitioners cite that was not known to and considered by the Court whose Members actually lived through the Civil War and Reconstruc- tion. Adopting petitioners’ view would throw into doubt the rights of aliens and corporations; make the Grand Jury Clause and Seventh Amendment appli- cable to the States; and unsettle the legal status of unenumerated rights, both those that have been recognized and those that have not. Stare decisis concerns are of overwhelming force in this case.

 

Overruling Slaughter-House and its progeny at this late date would upset strong reliance interests, throw the structure of constitutional law applicable to the States into disarray, and serve no useful purpose.

Furthermore, to call Slaughter-House venerable is tenuous. It is almost universally reviled and disagreed with. But, reinvigorating the privileges or immunities clause need not necessarily upset the apple cart. The Respondents insist that PEtitioners argue that the entire Due Process Jurisprudence should be displaced. Such is not the case. In fact, Gura is very careful to say that the two doctrines can live side by side. The Pandora’s Box Respondent’s fear is not even hinted at by Gura and the Petitioners.

 

6. Sixth, Respondents also argue that the right to keep and bear arms should mean different things in different places, based on local concerns.

 

Firearms are designed to injure or kill; conditions of their use and abuse vary widely around the country; and different communities may come to widely varying conclusions about the proper approach to regulation. Although other approaches are possible and may be effective elsewhere, it cannot be concluded that easy and widespread availability of firearms everywhere is necessary to ordered liberty.

I have blogged about this elsewhere, but I reject the notion that the Constitution has a “geography clause.” A right to be free from unreasonable searches and seizures should mean the same thing in Chicago as it does in Cheboygan. The Second Amendment should receive the same treatment.

 

7. Seventh, I’m not quite sure why, but the brief sees fit to discuss international gun control laws in England, Canada, and Australia.

 

The legal systems of England, Canada, and Australia each have their roots in the same English law as does this country, and each should be seen as a country in which “ordered liberty” is valued. Yet each of them imposes stringent regulations on firearms that would be impermissible or at least suspect under Second Amendment standards.

 

That these countries have a similar common law origin is largely irrelevant. Since our separation from the Queen two centuries ago, our nations have diverged in may aspects, especially in gun rights.

 

In summary, the Constitutional Law in this brief is at a real premium. It is mostly a policy argument about the dangers of legalizing guns, an argument that has been fought, and in my opinion, lost in Heller.

 

I’ll provide some more analysis later.

 

In a word, fail.

[lockman]

In a word, fail.

 

:Crying. =-(:

[pyre400]

I’ll provide some more analysis later.

 

In a word, fail.

 

I agree with your analysis. The brief was actually pretty pitiful.

 

The argument about the "English traditions" and how the UK, Canada, and Australia have gun bans - so should the US. The gun bans where what, in the last couple of decades or less...

 

The reduction in "public fear" was just as laughable too (people feel really safe in Chicago right now)

They argue that Chicago has special circumstances - while guns would be ok somewhere else. That, in my mind, clearly defines their delusional thinking. The guns can be obtained anywhere, how effective is your ban, really?

They cite crime statistics and how handguns are mostly used in crime . Hmmm, crimes are committed with guns because the only people who have handguns in Chicago are the criminals? Ever think of that?

 

The "common language" attack... nearly childish.

 

Content aside, I dont think this brief was written nearly as well as the plaintiff's. Even judge wap would feel insulted. I must say, I'm embarrassed for Chicago... A perfect example of more tax dollars at work. They must take the SCOTUS Justices for morons.

 

All that said, its hard to make a good argument when you are fundamentally wrong to begin with.

[GarandFan]

Hi folks:

 

Good to see this commentary here ... lots of folks have been forward to seeing this brief! Good thing Chicago was granted another 2 weeks to prepare it, huh? ;-)

 

I am vacationing and have not been able to read all of it yet. It seems to be a bit all over the place, and there seem to be some serious inconsistencies in the brief. Moreover ... it seems that, again, they are arguing points that have clearly been foreclosed by Heller. Also, the information on "firearms as social cost" was also presented during the Heller case ... and roundly ignored by the majority at least ... because the policy issues surrounding crime are just questions not on the table. I guess they might be a little more on the table in this case than the threshold Heller case ... but still. Perhaps that is just fodder for the dissenting justices. These briefs are "dances" really.

 

Also ... I thought that their brief at the petition stage was better written and argued than this one. There just seems a lot of extraneous material in there, which in comparison makes the SAF/ISRA and the NRAs briefs look professional, concise, and convincing.

 

More later ... but I am pleased with the quality of Chicago's brief (meaning it's not as "good" as I had thought it might be).

 

Happy New Year!!

[Sigma]

So basically they wrote that guns are bad and we dont like em. I thought they were supposed to be showing how the 14th doesn't apply or atleast why it shouldn't.

How did the lower courts ever uphold this ban if this is the kind of stuff they are writing?

I hope when they read ours they will see no response to the crap they wrote and simply deal with the 14th amendment applying ot the states.

[SFC Stu]

Keep and carry in case of confrontation. Notice they argue about may issue vs shall issue.

 

They bring in the in common use and get to the modern firearms. They even dance around machineguns tryign to scare the court.

 

How scary can it realistically be considering 42 states allow possession of machine-guns and only 9 states are may issue.

 

I do think they are scared and don't have a leg to stand on.

 

This is not about machine guns!

[GarandFan]

Reading Chicago's brief, I have found references to amicus briefs to be filed on their behalf (later today). Surely the following represents only some of the briefs that will be filed.

 

Unless I have missed some, 8 briefs were cited by Chicago:

 

Brief of the Association of Prosecuting Attorneys as Amicus Curiae in Support of Respondents

 

Brief of Professors of Criminal Justice as Amici Curiae in Support of Respondents

 

Brief of Chicago Board of Education, et al., as Amici Curiae in Support of Respondents

 

Brief of Oak Park Citizens’ Committee for Handgun Control as Amicus Curiae in Support of Respondents

 

Brief of United States Conference of Mayors as Amicus Curiae in Support of Respondents

 

Brief for the States of Illinois, et al., as Amici Curiae in Support of Respondents

 

Brief of Professional Historians and Legal Historians as Amici Curiae in Support of Respondents

 

Brief of Legal Scholars as Amici Curiae in Support of Respondents

 

 

And by the way, I found one of Chicago's most astoundingly disingenuous claims to be this statement ... see bolded text in particular:

 

Handgun restrictions can be an effective tool for curbing criminal street gangs, a major source of crime and violence in Chicago. When the police see gang members suspected of carrying guns, they can make an arrest and remove the gun from the street. This makes it riskier for gang members to ply their trade outdoors, thus making the streets safer. Criminal street gangs with the right to carry guns could use those guns to increase fear in their communities and violence used to control the drug trade that is their lifeblood.

 

Yeah ... as if incorporation of the 2A would restore gun rights to criminals.

[Yas]

Criminal street gangs with the right to carry guns could use those guns to increase fear in their communities and violence used to control the drug trade that is their lifeblood.

 

Yeah ... as if incorporation of the 2A would restore gun rights to criminals.

 

So If they lose the decision, is this an admittance by the City's atty's that the right is to carry?

[GarandFan]

Criminal street gangs with the right to carry guns could use those guns to increase fear in their communities and violence used to control the drug trade that is their lifeblood.

 

Yeah ... as if incorporation of the 2A would restore gun rights to criminals.

 

So If they lose the decision, is this an admittance by the City's atty's that the right is to carry?

 

No ... it's her admittance that she wants to ensure the Justices know she's a freaking idiot (and/or a wholly dishonest one).

[GarandFan]

And by the way, I found one of Chicago's most astoundingly disingenuous claims to be this statement ... see bolded text in particular:

 

Handgun restrictions can be an effective tool for curbing criminal street gangs, a major source of crime and violence in Chicago. When the police see gang members suspected of carrying guns, they can make an arrest and remove the gun from the street. This makes it riskier for gang members to ply their trade outdoors, thus making the streets safer. Criminal street gangs with the right to carry guns could use those guns to increase fear in their communities and violence used to control the drug trade that is their lifeblood.

 

That ... and their appeal to Josh Sugarmann as an authority regarding the efficacy of defensive firearms and their use. Sheesh ...

[lockman]

And by the way, I found one of Chicago's most astoundingly disingenuous claims to be this statement ... see bolded text in particular:

 

Handgun restrictions can be an effective tool for curbing criminal street gangs, a major source of crime and violence in Chicago. When the police see gang members suspected of carrying guns, they can make an arrest and remove the gun from the street. This makes it riskier for gang members to ply their trade outdoors, thus making the streets safer. Criminal street gangs with the right to carry guns could use those guns to increase fear in their communities and violence used to control the drug trade that is their lifeblood.

 

Yeah ... as if incorporation of the 2A would restore gun rights to criminals.

 

Won't this criminal right to bear arms have a noticeable impact on our prison system?

[ming]

With the amici briefs for City of Chicago due soon, I wonder how much SCOTUS is influenced by briefs from either side, or even if they are influenced at all. After all, SCOTUS members have had many years in the judicial system. Are their minds made up already? I can't say I follow SCOTUS closely so I would like to get some opinions on this. Do amici briefs convince jurists, or for that matter, does even oral argument sway them? Or is it that briefs/oral argument only help them in writing up their preconceived legal opinions either for/against plaintiffs?

[Federal Farmer]

With the amici briefs for City of Chicago due soon, I wonder how much SCOTUS is influenced by briefs from either side, or even if they are influenced at all. After all, SCOTUS members have had many years in the judicial system. Are their minds made up already? I can't say I follow SCOTUS closely so I would like to get some opinions on this. Do amici briefs convince jurists, or for that matter, does even oral argument sway them? Or is it that briefs/oral argument only help them in writing up their preconceived legal opinions either for/against plaintiffs?

 

Cynical followers of SCOTUS will tell you that the justices mine the amici for elements supporting their preconceived opinions.

[Ashrak]

7. Seventh, I’m not quite sure why, but the brief sees fit to discuss international gun control laws in England, Canada, and Australia.

 

It is a pandering effort directed at Ginsburg (and maybe Sotomayor as well).

[Ashrak]

Won't this criminal right to bear arms have a noticeable impact on our prison system?

Why, one could say, as Durbin and Quinn have, that such a happening would be a positive economic development. jobs jobs jobs jobs jobs jobs........

')

[Federal Farmer]

As of this posting there are 5 Chicago amici posted on http://www.chicagoguncase.com.

 

54 US Representatives signed onto one in particular that attempts to respond to the massively more broadly supported McDonald Congressional amicus.

[Federal Farmer]

OMG, the ADL brief seems focused on raising fears about violent extremists. I'd paste excerpts except I can't do that from my machine at work.

[Federal Farmer]

5 Second Summaries.

 

ADL: OMG Racists!

Josh Horowitz: OMG Insurrectionist!

Mayors: OMG Criminals!

54 Reps: OMG Guns in the Mail!

Public Health: OMG Suicide!

[05FLHT]

5 Second Summaries.

 

ADL: OMG Racists!

Josh Horowitz: OMG Insurrectionist!

Mayors: OMG Criminals!

54 Reps: OMG Guns in the Mail!

Public Health: OMG Suicide!

 

That's seriously funny stuff there!

[Sigma]

Does those 54 Representatives carry any weight?

Also I do believe they already have thier mind made up. For example, there is nothing that you could say to convince Sotomayer that guns aren't evil. She can read and hear all the oral arguments you want she wont be on our side.

[Thirdpower]

Giving a quick overview of most of them, they all seem to be trying to re-enforce the points in the Chicago brief. ie, they're trying to re-argue Heller via the collective rights bit.

[mikew]

OMG, the ADL brief seems focused on raising fears about violent extremists. I'd paste excerpts except I can't do that from my machine at work.

As a Jew, I find the ADL brief embarrassing.

Are they talking about the JDL? :-)

[lockman]

In the States' filing just the intro throws these at you:

 

Don't incorporate, it might be costly to fight the challenges.

 

"Finally, because the States have long regulated firearms without federal interference,..." Really? Is that why I never have a problem buying handguns and machine-guns through the mail or from an out of state source?

 

The very beginning of the argument quotes the dissenting opinion of justice Brandeis in New State Ice Co. v. Liebmann.

 

 

 

Maybe I am getting lazy but after reading two of them I feel it is a waste of my time. I will let other forge ahead and get the quick revue. So far FF seems to be right on. If anything else needs attention I am sure one of our members will catch it.

[Federal Farmer]

Many more Chicago amici are posted.

 

http://www.chicagoguncase.com/wp-content/u...dguncontrol.pdf

 

I find it amusing (?) that the Oak Park Citizens Committee For Handgun Control, allegedly a grassroots organization is based in Chicago.

[Howard Roark]

Twisted! Little mikey quigly (D-Chicago/Illinois) quoting Sen. Strom Thurmand (R-South Carolina) chapter and verse about why the States can nullify the Second Amendment through legislation?! Now, I think I've seen it all. The argument that the historical Southern states rights position that the Bill of Rights didn't apply was wiped out by the 14th. But little "quig" goes quoting Sen. Strom to defend Chicago ban on the Already-Declared-Individual-Right-To-Handguns-Via-Heller !

 

Homer Simpson would say, "Doh!". I'm not linking to the pathetic brief, you can find it in the garbage heap, but don't bother.

 

OK, here is the brief of Lil' Quig quotin' Senator Strom Thurmond:

 

In the debates preceding the passage of the 1968

legislation, legislators from both parties uniformly

expressed support for local legislation in this area.

As Senator Thurmond argued, “Conditions and

traditions vary widely from State to State, and the

needs of one State should not necessarily be imposed

upon another. The Federal Government should take

no measures which pressure or require States to

adopt uniform Federal standards.”25

 

But the Gun Control Act of 1968 was a prohibitionist measure, and Senator Turmond was saying "leave South Carolina Out of your prohibitionist laws". Yet, Lil' Quig tries to spin it as if Sen. Strom supported laws that lead to Chicago's total ban on civilian handguns (except for Alderman of the City Council and police). What a big lie and mis-quotation!

 

Here is Sen. Strom Thurmond a couple of years after the GCA of 1968:

 

US Senate - GCA - Comments

 

The US Senate Judiciary Committee of 1982 clearly supports the individual right to keep and bear arms in all the 50 states. Read it yourself. The brief from Lil' Quig is a farce in this misquotation. Nobody but Mr. Stupid believes that U.S. Senator Strom Thurmond (R of South Carolina) supported gun prohibition by the states or cities. It's an obvious lie. What a pathetic brief. Pfffffttttt.

[Federal Farmer]

Even funnier is the Chicago Board of Education brief is joined by dozens of Joyce Foundation puppet organizations, several of whom have been merged this year due to, apparently, funding cutbacks.

[GarandFan]

OMG, the ADL brief seems focused on raising fears about violent extremists. I'd paste excerpts except I can't do that from my machine at work.

As a Jew, I find the ADL brief embarrassing.

Are they talking about the JDL? :-)

 

I have now read the tables of content for all 16, and the summaries for most. To be sure, there is material there that the dissenting Heller justices will or may use. But there is also a great amount of deception, some sophisticated and some blatantly obvious.

 

In response to mikew's comment...the ADL brief is wholly pathetic. First, while hate groups are an important issue, interpretation of the constitutional question at issue will not turn on policy regarding hate groups.

 

Also, their argument is astounding in that it attempts to turn history on it's head. They argue that a reinforcement of our right to arms is impermissible because it might facilitate violence perpetuated against minorities. Yet anyone with a whit of history knows that one of the main reasons for the 14A was precisely to ensure that minorities could exercise their right to arms for the purpose of their own defense against hate groups.

 

It is not far-fetched to predict the court might include "ADL Brief" and "laughable" in the same sentence of their descision.

[Ranger]

As a Public Health Administrator, I am once again ashamed of and disgusted with the American Public Health Association. It has repeatedly proven itself to be an organization out of touch with its alleged constituency. For years now, I've refused to renew membership to APHA and have sometimes debated whether to maintain membership with IPHA (state association). Years ago, I was on a team with the MidAmerica Leadership Institute. Our project was related to suicide and gun availability. Some members of the team went into the project assuming guns were bad (included people from Chicago area). In fact, probably at the first meeting, one member had already designed a logo with a pistol in a circle with a slash through it for our findings. Well... I purchased a bunch of books by Kleck, Kopel, others, did research, and our ultimate report was that there was no correlation. Suicide by firearms does have a higher success rate than many other methods; but the data is there to support that people will commit suicide by some means if they seriously want to do so.