context: By analogy, many courts have adopted intermediate scrutiny when evaluating restrictions on gun possession by particular people or in particular places. In Laurent, for example, the court considered a Second Amendment challenge to a ban on receipt of fire arms by a person who is under indictment for a crime punishable by imprisonment for more than one year.
citation_a.signal: no signal
citation_a.identifier: 638 F.3d 458, 471
citation_a.parenthetical: reviewing under intermediate scrutiny a former federal regulation that prohibited carrying or possessing a loaded weapon in a motor vehicle within national park areas
citation_a.sentence: Id.', see also Reese, 627 F.3d at 801, 802 (considering under intermediate scrutiny a law prohibiting possession of a firearm by a person subject to a domestic protection order); United States v. Masciandaro, 638 F.3d 458, 471 (4th Cir. 2011) (reviewing under intermediate scrutiny a former federal regulation that prohibited carrying or possessing a loaded weapon in a motor vehicle within national park areas).
citation_b.signal: but see
citation_b.identifier: 614 F.3d 638, 641-42
citation_b.parenthetical: rejecting rational basis as the appropriate standard but otherwise avoiding "the levels of scrutiny' quagmire"
citation_b.sentence: But see United States v. Engstrum, 609 F. Supp. 2d 1227, 1231-32 (D. Utah 2009) (applying strict scrutiny to a statute banning persons convicted of misdemeanor domestic violence from possessing firearms); Nordyke v. King, 681 F.3d 1041,1044-45 (9th Cir. 2012) (declining to determine what type of heighted scrutiny applies to laws that substantially burden Second Amendment rights); United States v. Skoien, 614 F.3d 638, 641-42 (7th Cir. 2010) (rejecting rational basis as the appropriate standard but otherwise avoiding “the levels of scrutiny’ quagmire”).