A municipality’s community character is often now defined, at least in part, by its relationship to the Second Amendment. Some localities, like the newly self-labelled “Second Amendment Sanctuaries,” define themselves by their intense attraction to firearms and devotion to an unconstrained Second Amendment. Other localities, like large and liberal New York City or Chicago for example, head in the other cultural direction, adopting numerous gun control measures and preferring a more cabined version of gun rights to define their cultural identity.
When this latter type of locality is called to defend the constitutionality of a gun control measure, courts continually struggle with the following question: does it matter that whatever is being limited can be easily accessed beyond a locality’s borders? So, for instance, can one locality prohibit firing ranges, as long as an adjoining jurisdiction has plenty of them readily accessible?