Is a state law that prohibits the carrying of concealed firearms in a vehicle within the scope of the Second Amendment?

^4. In one California case, People v. Ellison (2011) 196 Cal.App.4th 1342, the court assumed that a state law prohibiting the carrying of a concealable firearm in a vehicle was within the scope of the Second Amendment and opted to review the law under the " 'intermediate scrutiny' " standard. (Id. at p. 1347.) Applying this standard, the court found the prohibition constitutional because it "d[id] not substantially burden defendant's exercise of his Second Amendment right." (Id. at p. 1351.) We, however, are persuaded that the laws here fall outside the reach of the Second Amendment, and thus we need not evaluate whether they pass intermediate or heightened scrutiny.