The following excerpt is from United States v. Fierro-Morales, CASE NO. 17CR3096 WQH (S.D. Cal. 2018):
of the inquiry to determine appropriate level of scrutiny to apply. See Mahoney v. Sessions, 871 F.3d 873, 878-80 (9th Cir. 2017) (proceeding to the second step because the employer policy resembled none of the presumptively lawful measures identified in Heller and the parties adduced no evidence that the policy fell outside the historical scope of the Second Amendment right to use a firearm for self-defense).
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