Second Amendment sanctuary

From Wikipedia, the free encyclopedia

Second Amendment sanctuary (SAS), also known as a gun sanctuary, is a state, county or locality in the United States that has adopted laws or resolutions that oppose, or purport to prohibit or impede, law enforcement agencies within that state, county or locality from assisting in the enforcement of certain gun control measures enacted by other governmental bodies. Proponents of such "sanctuary" laws or resolutions contend that various gun laws—such as universal background checks, high-capacity magazine bans, assault weapon bans, red flag laws—are a violation of the rights guaranteed within the Second Amendment.[1][2][3]

Although other jurisdictions had previously adopted legislation now characterized as creating Second Amendment sanctuaries, the Carroll County, Maryland Board of Commissioners is thought to be the first body to explicitly use the term "sanctuary" in its resolution on May 22, 2013,[4] while Bryan Kibler, the state's attorney in Effingham County, Illinois is thought to have popularized the term to describe the county's April 2018 resolution,[3][5][1][6] although equivalent resolutions (not using the "sanctuary" phrase) predated the Effingham County measure.[3] The term "sanctuary" draws its inspiration from the immigration sanctuary cities movement of jurisdictions that have resolved to not assist federal immigration enforcement.[3][7][8][9] As of 2021, about 1200 local governments in 42 states have adopted such resolutions.

Second Amendment sanctuary resolutions are primarily expressive and symbolic.[3][10] Virginia Attorney General Mark Herring issued an opinion in 2019 stating that the resolutions "have no legal force."[3] Some counties that have passed gun sanctuary resolutions have acknowledged that the resolutions are declarations rather than legally binding measures; other resolutions contain specifics stating how the local government will not cooperate with state or federal gun laws.[3] The Second Amendment sanctuary movement has some connections to the "constitutional sheriffs movement" (sheriffs in some rural counties who have publicly declared that they would refuse to enforce new gun laws).[3]

On March 31, 2021 Columbia County, Oregon requested a judicial review of its Second Amendment sanctuary law. "This will allow the court to tell us whether the county can actually decline to enforce certain state laws, and it will tell us how to abide by the will of the voters to the extent that we can," explained Sarah Hanson, counsel for the county.[11][12]

State laws[]

Although some of the state laws listed below were approved prior to the adoption of the term "sanctuary",[13][14] they are now frequently characterized as part of the Second Amendment sanctuary movement.[5][1] Montana was the first state to attempt passage of such bills in 2005, eventually passing in 2009, though it ended up being struck down by the Ninth Circuit Court of Appeals.[15]

SanctuaryCounties.com, a pro-Second Amendment website tracking the sanctuary counties movement, defines the resolutions will not be enforcing any new gun laws cooked up by this administration or any future administration. We’d like to see clauses indicating that no state funds, nor state personnel will be utilized to implement any new gun laws and that any law enforcement officer in your state who attempts to enforce such laws will lose their ability to work in law enforcement in your state. We’d also like to see clauses indicating that there will be no collaboration with any federal law enforcement agencies for the purposes of enforcing any new gun laws.

Alaska[]

On July 9, 2010, Governor Sean Parnell signed the Alaska Firearms Freedom Act (HB 186), declaring that certain firearms and accessories are exempt from federal regulation.[16][17] On September 10, 2013, Parnell signed HB 69, which amended and expanded the Alaska Firearms Freedom Act.[18][19][20]

Arizona[]

On April 5, 2010, Governor Jan Brewer signed HB 2307 which exempted intrastate firearms from federal law.[21] On April 6, 2021, Governor Doug Ducey signed the 2nd Amendment Firearm Freedom Act (HB 2111), which prohibits the state and all political subdivisions from assisting in the enforcement of federal firearm laws and regulations when they are inconsistent with state law.[22][23] On June 22, 2021, the city of Tucson passed a resolution to ignore the statewide Second Amendment sanctuary law.[24]

Arkansas[]

On April 26, 2021, Governor Asa Hutchinson vetoed SB298, The Arkansas Sovereignty Act Of 2021. The Senate promptly overrode the governor's veto later the same day.[25][26][27] The House decided to postpone its veto override vote and instead, on April 27, passed HB1957, a less expansive version of the bill; the Senate then passed it as well shortly after midnight on April 28.[28] The governor signed it on April 29, 2021.[29][30]

Idaho[]

On March 19, 2014, Governor Butch Otter signed SB 1332 to protect Idaho law enforcement officers from being directed by the federal government to violate citizens' rights under Section 11, Article I of the Idaho Constitution.[31][32][33] Previously, HJM 3 was passed in 2009[34][35] and HB 589 in 2010.[36]

Kansas[]

On April 16, 2013, Governor Sam Brownback signed SB 102, also known as the Second Amendment Protection Act (SAPA).[37][38][39] A seller and buyer of a silencer, while complying with the SAPA but not with federal law on silencers, were prosecuted in federal court.[40]

Missouri[]

On June 12, 2021, Governor Mike Parson signed the Second Amendment Preservation Act (HB 85), which will "reject any attempt by the federal government to circumvent the fundamental right Missourians have to keep and bear arms to protect themselves and their property."[41][42][43] A similar bill had been passed in 2013, but was vetoed; a veto override passed in the House but failed by 1 vote in the Senate.[44][45]

Montana[]

On April 23, 2021, Governor Greg Gianforte signed HB 0258 banning the enforcement of federal bans on firearms, magazines, or ammunition. The bill applies retroactively to January 1, 2021.[46][47][48][49] Previously, Montana had passed the Montana Firearms Freedom Act (HB 246) in 2009 which exempted from federal law firearms manufactured within the state and that remain in the state.[50] The law was subsequently struck down by the Ninth Circuit Court of Appeals.[51]

Nebraska[]

On April 14, 2021, Governor Pete Ricketts signed a proclamation that designated Nebraska as a "Second Amendment Sanctuary State."[52] This proclamation is merely symbolic and does not carry the weight of law.

North Dakota[]

On April 22, 2021, Governor Doug Burgum signed HB 1383, which limits enforcing or assisting in the enforcement of federal firearms laws enacted after January 1, 2021, that are more restrictive than state law.[53] On April 26, 2021, Burgum also signed a proclamation which designated North Dakota as a "Second Amendment Sanctuary State."[54][55]

Oklahoma[]

On April 26, 2021, Governor Kevin Stitt signed the Second Amendment Sanctuary State Act (SB 631) which prevents the confiscation or surrender of firearms, gun accessories, or ammunition from law-abiding Oklahomans, protecting the right to keep and bear arms guaranteed by the United States Constitution.[56][57] In May 2020, Oklahoma became the first and thus far only state to enact an anti-red flag law. The law specifically "prohibits the state or any city, county or political subdivision from enacting red flag laws."[58][59]

South Carolina[]

On May 17, 2021, Governor Henry McMaster signed H.3094, also known as the Open Carry With Training Act. Section 9 of H.3094 notes "the state of South Carolina and its political subdivisions cannot be compelled" to enforce federal laws that regulate an individual's right to carry concealable weapons openly or concealed. Any such law must first be evaluated by the Attorney General who shall issue a written opinion on if it can be enforced.[60][61][62]

South Dakota[]

On March 12, 2010, Governor Mike Rounds signed SB 89.[63] However, SanctuaryCounties.com, a website tracking the sanctuary county movement, does not consider this a Second Amendment Sanctuary law, stating that it's more about firearm and ammunition manufacturers being able to operate in the state in spite of federal regulation, rather than protecting the Second Amendment rights of the state citizens.[64]

Tennessee[]

On May 26, 2021, Governor Bill Lee signed the "Tennessee Second Amendment Sanctuary Act" (SB 1335) which prohibits Tennessee or any of its subdivisions from enforcing "any law, treaty, executive order, rule, or regulation of the United States government that violates the Second Amendment".[65][66] Previously, the Tennessee Firearms Freedom Act was passed in 2009.[67][68]

Texas[]

On June 17, 2021, Governor Greg Abbott signed "Second Amendment Sanctuary State Act" (HB 2622) which prohibits the enforcement of certain federal regulations on firearms, firearm accessories, or ammunition that are not in state law.[69] He also signed HB 957 which exempts from federal law suppressors manufactured within the state and that remain in the state, and prohibits the state from enforcing federal law against suppressors. Federal agents could, however, still try to enforce federal law.[70][71]

Utah[]

On February 26, 2010, Governor Gary Herbert signed the Utah State-made Firearms Protection Act (SB 11).[72] However, like South Dakota's law, SanctuaryCounties.com does not consider this a Second Amendment Sanctuary law on the grounds that it is more about protecting firearm and ammunition manufacturers than Second Amendment rights of state citizens.[64]

West Virginia[]

On April 27, 2021, Governor Jim Justice signed the Second Amendment Preservation and Anti-Federal Commandeering Act (HB 2694) which prohibits the federal commandeering of employees and agencies of the state for the purpose of enforcing federal firearms laws. HB 2694 also prohibits police departments and officers from executing red flag laws or federal search warrants on firearms, accessories, or ammunition of law abiding persons.[73]

Wyoming[]

On March 11, 2010, Governor Dave Freudenthal signed HB 0095, also known as the Wyoming Firearms Freedom Act.[74]

Local laws[]

Alabama[]

1 out of 67 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Alaska[]

2 out of 19 boroughs have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Arkansas[]

5 out of 75 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Arizona[]

7 out of 15 counties, 1 city, and 1 town have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[84]

California[]

3 out of 58 counties and 2 cities have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Colorado[]

39 out of 64 counties, 3 cities, and 4 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[100][101][102][103][104][105][106][107][108][109][110]

(Main reference: [111])

  • Alamosa
  • Archuleta
  • Baca
  • Bent
  • Cheyenne
  • Commerce City
  • Conejos
  • Crowley
  • Custer (plus Silver Cliff Town)
  • Delta
  • Dolores
  • Douglas
  • El Paso (plus Monument Town[112])
  • Elbert
  • Fremont(plus Cañon City)
  • Garfield
  • Huerfano
  • Jackson
  • Kiowa
  • Kit Carson
  • Las Animas
  • Lincoln
  • Logan
  • Mesa
  • Mineral
  • Moffat (plus Craig City)
  • Montezuma
  • Montrose
  • Morgan
  • Otero
  • Park
  • Phillips (plus Haxtun Town[109])
  • Prowers
  • Rio Blanco
  • Rio Grande
  • Sedgwick
  • Teller
  • Washington
  • Weld (plus Milliken Town)
  • Yuma[109]

Florida[]

44 out of 67 counties, 3 cities, and 1 town have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions.[113]

In 2013, all 67 sheriffs in Florida had signed a letter saying that they will not enforce laws that violate the Constitution or infringe on the rights of the people to own firearms.[114]

Georgia[]

48 out of 159 counties and 2 cities have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Idaho[]

7 out of 44 counties and 12 cities have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Illinois[]

71 out of 102 counties, 2 cities, 4 townships, and 1 village have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[233][234][235][236][237][238][239][240][241][242]

  • Adams
  • Bond
  • Boone
  • Brown
  • Bureau
  • Calhoun
  • Christian
  • Clark
  • Clay
  • Clinton
  • Coles
  • Crawford
  • Cumberland
  • Douglas
  • Edgar
  • Edwards
  • Effingham
  • Farmer City
  • Fayette
  • Ford
  • Franklin
  • Gallatin
  • Greene
  • Grundy
  • Hamilton
  • Hancock
  • Hardin
  • Henderson
  • Henry
  • Iroquois
  • Jasper
  • Jefferson
  • Jersey
  • Johnson
  • LaSalle
  • Lawrence
  • Lee
  • Livingston
  • Logan
  • Macon
  • Macoupin
  • Madison
  • Marion
  • Marshall
  • Massac
  • McDonough
  • McHenry Township[243]
  • McLean[244]
  • Mercer
  • Monroe
  • Montgomery (plus Hillsboro City)
  • Morgan (plus South Jacksonville Village[245])
  • Moultrie
  • O'Fallon Township
  • Ogle
  • Perry
  • Piatt
  • Pike
  • Plainfield Township
  • Pope
  • Pulaski
  • Randolph
  • Richland
  • Saline
  • Schuyler
  • Shelby
  • St. Clair Township
  • Stark
  • Tazewell
  • Union
  • Wabash
  • Washington
  • Wayne
  • White
  • Williamson
  • Woodford

Iowa[]

14 out of 99 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Adams, Carroll, Chickasaw, Cedar, Clarke, Hardin Jasper, Kossuth, Madison, Mills, Mitchell, Pocahontas, Washington, and Wayne Counties.[246]

Indiana[]

30 out of 92 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:


Kansas[]

5 out of 105 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Kentucky[]

113 out of 120 counties and 6 cities have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[286]

Louisiana[]

5 out of 64 parishes have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

  • St. Mary[386][387]
  • Vernon Parish
  • Winn Parish
  • Rapides Parish
  • Grant Parish

Maine[]

1 out of 16 counties, 1 city, and 7 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Maryland[]

12 out of 23 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Michigan[]

50 out of 83 counties, 1 city, and 5 townships have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions. On February 25, 2020, the Michigan House of Representatives voted to reaffirm the Second Amendment.[409] The text can be read here.[410]

Minnesota[]

16 out of 87 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[467]

Mississippi[]

27 out of 82 counties have adopted Second Amendment sanctuary, safe haven, or other pro-Second Amendment resolutions:

Missouri[]

14 out of 114 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Nebraska[]

81 out of 93 counties and 1 city have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Nevada[]

10 out of 16 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions.[599][600][601][602][603][604][605][606][607]

All 17 sheriffs in Nevada (16 county and 1 Carson City) and have signed a letter expressing their support for the Second Amendment.[608]

  • Douglas
  • Elko
  • Eureka
  • Humboldt
  • Lander
  • Lincoln
  • Lyon
  • Nye
  • Pershing
  • White Pine


New Jersey[]

8 out of 21 counties, 4 cities, 39 townships, 1 town, and 6 boroughs (50 of 565 total municipalities) have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[609]

  • Atlantic[610] (plus Absecon City,[611] Corbin City, Egg Harbor Township, Mullica Township, Northfield City,[612] Port Republic City,[613] and Weymouth Township[614])
  • Bass River Township
  • Cape May[615] (plus Dennis Township,[616] Lower Township, Middle Township, and Upper Township
  • Cumberland[617] (plus Commercial Township, Deerfield Township, Downe Township, Lawrence Township, Maurice River Township,[618] and Stow Creek Township)
  • Franklin Township (Gloucester County)[619]
  • Monmouth[620][621] (plus Howell Township)
  • Monroe Township (Gloucester County)
  • Ocean[622] (plus Barnegat Township,Berkeley Township, Jackson Township,
  • Lacey Township and Little Egg Harbor Township[623])
  • Salem[624] (plus Alloway Township,[618] Elmer Borough,[625] Lower Alloways Creek Township, Pennsville Township, Pittsgrove Township,[626] and Upper Pittsgrove Township)
  • Sussex[627] (plus Branchville Borough,[628] Frankford Township, Franklin Borough,[618] Fredon Township, Hamburg Borough,[618] Hampton Township, Hardyston Township, Hopatcong Borough,[629] Montague Township,[628] Stillwater Township,[628] Sussex Borough,[630] and Wantage Township
  • Tabernacle Township
  • Warren[631] (plus Hope Township, Oxford Township,Phillipsburg Town,[632][633] and Washington Township)
  • West Milford Township[634][635]

New Mexico[]

26 out of 33 counties, 6 cities, and 1 town have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions;[636][637] Taos initially passed a resolution[638] but later repealed it.[639]

30 out of 33 county sheriffs have signed a letter by the New Mexico Sheriffs Association vowing to not assist in enforcing certain gun control.[640]

New York[]

County opposition to SAFE Act

The SAFE Act was passed in 2013. After passage, New York counties started passing resolutions opposing the SAFE Act. There are currently 52 out of 62 counties with such resolutions.

2 out of 62 counties and 3 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[650]

North Carolina[]

76 out of 100 counties, 1 city, and 2 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[654][655]

North Dakota[]

3 out of 53 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Ohio[]

34 out of 88 counties, 1 city, and 3 townships have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Oklahoma[]

40 out of 77 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[729]

Oregon[]

27 out of 36 counties and 3 cities have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[762][763][764][765]

Pennsylvania[]

14 out of 67 counties, 17 townships, and 4 boroughs have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Rhode Island[]

0 out of 8 cities and 10 out of 31 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions;[816][817] while Rhode Island has 5 counties, there is no local government at that level.[818]

South Carolina[]

8 out of 46 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

South Dakota[]

8 out of 66 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Tennessee[]

68 out of 95 counties, 3 cities, and 1 town have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[837][838][839][840][841][842][843][844][845]

Texas[]

86 out of 254 counties, 1 city, and 2 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[902][903][904][905][906][907][908][909][910]

(Main reference:[911][912])

  • Anderson[913]
  • Angelina
  • Atascosa
  • Bandera[914]
  • Bowie[915]
  • Brown
  • Burleson[citation needed]
  • Burnet[916]
  • Calhoun
  • Callahan
  • Cass
  • Cherokee (plus Wells Town[917])
  • Clay
  • Coke
  • Coleman
  • Collin
  • Colorado
  • Cooke[752]
  • Coryell
  • Dallam[918]
  • Dawson[919]
  • Denton
  • Eastland
  • Edwards
  • Ellis
  • Erath
  • Fannin
  • Freestone
  • Gonzales
  • Grimes
  • Hemphill[920]
  • Hood
  • Hopkins
  • Houston
  • Howard (plus Big Spring City)
  • Hudspeth
  • Hunt
  • Hutchinson
  • Jack
  • Jackson
  • Johnson
  • Kaufman
  • Kinney[921]
  • Knox[921]
  • Lamar
  • Lavaca[921]
  • Leon
  • Lipscomb[922]
  • Llano[923]
  • Madison
  • Marion
  • McCulloch
  • Milam
  • Mitchell
  • Montgomery
  • Moore[924]
  • Navarro
  • Nolan
  • Palo Pinto
  • Panola
  • Parker
  • Pecos[925]
  • Presidio
  • Rains[926]
  • Real[925]
  • Red River
  • Rockwall[921]
  • Sabine[927]
  • San Saba[928][929]
  • Shackelford
  • Shelby
  • Smith
  • Stephens
  • Sterling[930]
  • Throckmorton[931]
  • Titus
  • Tyler[932] (plus Chester Town)
  • Upshur
  • Van Zandt
  • Victoria
  • Walker
  • Waller
  • Washington[933]
  • Wise[921]
  • Wood
  • Young

Utah[]

17 out of 29 counties and 1 city have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:
All 29 sheriffs in Utah have signed a letter expressing their support for the Second Amendment.[934]

Vermont[]

0 out of 14 counties and 21 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Virginia[]

91 out of 95 counties, 16 out of 38 independent cities, and 42 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:[967][968][969][970]

(Main citation for all counties:[971])

On December 19, 2019, at the request of Del. Jerrauld C. Jones (D-Norfolk), state Attorney General Mark Herring issued an advisory opinion indicating the sanctuary resolutions were null and void.[1019][1020] A press release quoted him as saying: “When the General Assembly passes new gun safety laws they will be enforced, and they will be followed. These resolutions have no legal force, and they're just part of an effort by the gun lobby to stoke fear”.[1019][1020] Del. Todd Gilbert (R-Shenandoah) claimed that Herring's recent opinion contradicted his 2014 stance "regarding the supremacy of state law over the preferences of the officials who must enforce them".[1020] Gilbert was referring to Herring's refusal to defend Virginia's Marshall-Newman Amendment, a voter-approved constitutional provision that prohibited same-sex marriages.[1020][1021]

West Virginia[]

37 out of 55 counties, 3 cities, and 3 towns have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Wisconsin[]

20 out of 72 counties, 1 city, 5 towns, and 1 village have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Wyoming[]

11 out of 23 counties have adopted Second Amendment sanctuary (or other pro-Second Amendment) resolutions:

Local law enforcement resistance[]

Washington[]

23 county sheriffs out of 39 counties and the police chief of 1 city have vowed to not enforce parts or all of the 2018 gun control ballot measure I-1639 while it is being challenged in court:[1103][1104][1105][1106]

  • Adams
  • Benton
  • Chelan
  • Columbia[1107][1108]
  • Cowlitz
  • Douglas[1109]
  • Ferry (plus Republic City)
  • Franklin
  • Grant
  • Grays Harbor
  • Kittitas
  • Klickitat
  • Lewis
  • Lincoln
  • Mason
  • Okanogan
  • Pacific
  • Pend Oreille
  • Skamania
  • Spokane
  • Stevens (resolution)[1110]
  • Wahkiakum
  • Yakima

Further reading[]

SECOND AMENDMENT SANCTUARIES by Shawn E. Fields; Northwestern University Law Review, Vol. 115, No. 2

References[]

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  2. ^ Penzenstadler, Nick (May 20, 2019). "NRA helps sheriffs fight gun laws in Second Amendment 'sanctuaries'". USA Today. Retrieved May 21, 2019.
  3. ^ a b c d e f g h Jennifer Mascia (January 14, 2020). "Second Amendment Sanctuaries, Explained". The Trace. The newer, Second Amendment type of sanctuary refers to a city, town, or county that has adopted a resolution rejecting the enforcement of state or federal gun laws perceived to violate the Second Amendment. Targeted regulations commonly include red flag laws, universal gun background checks, and bans on assault-style weapons.
  4. ^ a b "Commissioners Declare Carroll County a 'Second Amendment Sanctuary'". Westminster, MD Patch. May 24, 2013. Retrieved February 21, 2020.
  5. ^ a b Rosenberg-Douglas, Katherine (April 17, 2019). "Second Amendment 'sanctuary county' movement expands as organizers take aim at new gun laws". Chicago Tribune. Retrieved December 27, 2019.
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  7. ^ Andrea Diaz and Marlena Baldacci. "In rural Illinois, officials are creating 'sanctuary' counties to protect gun owners from new laws". CNN. Retrieved February 22, 2019.
  8. ^ "Illinois county votes to become 'sanctuary county' for gun owners". USA Today. Retrieved February 22, 2019.
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  10. ^ Ryan W. Miller, Virginia counties are declaring themselves 'sanctuaries' for Second Amendment. Will it affect gun laws?, USA Today (December 11, 2019).
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  30. ^ "HOUSE BILL 1957".
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  36. ^ "Idaho H0589 | 2010 | Regular Session". LegiScan. Retrieved July 2, 2021.
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  38. ^ Boldin, Michael. "Kansas Governor Sam Brownback Signs 2nd Amendment Protection Act into Law". Tenth Amendment Center Blog. Retrieved March 10, 2019.
  39. ^ "SB102" (PDF).
  40. ^ "2 Kansas men 'collateral damage' in gun control dispute". AP NEWS. June 16, 2019. Retrieved July 2, 2021.
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  42. ^ "Missouri HB85 | 2021 | Regular Session". LegiScan. Retrieved June 30, 2021.
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  44. ^ Boldin, Michael (September 11, 2013). "Override: Missouri House Votes to Nullify Federal Gun Control | Tenth Amendment Center". tenthamendmentcenter.com. Retrieved July 2, 2021.
  45. ^ Levin, Sam. "Second Amendment Preservation Act Fails: Missouri Won't Ban Federal Gun Laws". Riverfront Times. Retrieved July 2, 2021.
  46. ^ "Montana becomes Second Amendment sanctuary, joining growing number of states fighting federal gun laws". www.msn.com. Retrieved April 25, 2021.
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