However, unlike handguns, short-barreled firearms are not “an entire class of
‘arms’ *** chosen by American society for [the] lawful purpose” of self-defense. See Heller 554
U.S. at 625, 628. Short-barreled firearms are regulated precisely because they are “concealable
weapon *** likely to be used for criminal purposes.” See United States v. Thompson/Center
Arms Co., 504 U.S. 505, 517 (1992) (explaining that short-barreled rifles are regulated under the
National Firearms Act (26 U.S.C. §§ 5841, 5845 (2018)) for this very reason). The sheer number
of registered short-barreled firearms does not undercut their dangerousness or the fact that they
are “not typically possessed by law-abiding citizens for lawful purposes.”4 See Heller, 554 U.S.
at 625, 628; see also People v. Dean, 207 Ill. App. 3d 640, 642 (1990) (noting that the UUW
statute “provides that a person in possession of a sawed-off shotgun *** has committed a crime.
No exceptions are allowed under this section because such weapons are considered to be
inherently dangerous to human life”).
People v. Smith, sawed off shotguns.pdf