Guns Safe Life, Inc. v. Village of Deerfield

This case presents question as to whether trial court properly found that 2018 total bans imposed by Village of Deerfield on assault weapons and large capacity magazines were preempted by section 13.1 of FOID Card Act and section 90 of Concealed Carry Act. Appellate Court, in partially reversing trial court, found that: (1) section 13.1 of FOID Card Act did not preempt all regulation of assault weapons by home rule units; (2) Deerfield, in its 2013 ordinance, regulated possession and ownership of assault weapons in manner that was inconsistent with FOID Card Act, and thus preserved its power to regulate assault weapons concurrently with State; (3) Deerfield's 2018 ordinances were amendments to 2013 ordinances, as allowed by section 13.1(e) of FOID Card Act; and (4) to extent that Deerfield's ban on large capacity magazines regulated ammunition for handguns, it was preempted in its application to holders of valid FOID cards and concealed carry licenses. (Partial dissent filed.)