White v. Illinois State Police

Dist. Ct. did not err in granting defendants’ motion to dismiss plaintiffs-applicant and Illinois State Rifle Association’s action, alleging that Illinois Firearm Concealed Carry Act was unconstitutional as violative of Second Amendment as applied to State’s denial of plaintiff-applicant’s second application for said license, where record showed that applicant had two criminal convictions, including one for unlawful use of firearm and had multiple gun-related arrests. As such, State’s individualized determination that applicant’s criminal history rendered him too dangerous to carry concealed firearm in public survived intermediate scrutiny. Ct. of Appeals further found that plaintiff-Rifle Association lacked standing to sue on its own behalf, when it did not allege injury to itself or request any relief. Moreover, Rifle Association lacked standing to sue on behalf of its members when it failed to either identify any member or explain how its members would have standing to sue in their own right. Ct. of Appeals also rejected applicant’s contention that Firearm Concealed Carry Act created de facto lifetime ban on his right to carry concealed firearm in public for self-defense.