generally unrestricted in the jurisdictions in question, which provided an alternative means of "bearing" arms. In the majority decision in the 2008 Supreme Court case of District of Columbia v. Heller, Justice Antonin Scalia wrote; Heller was a landmark case because for the first time in United States history a Supreme Court decision defined the right to bear arms as constitutionally guaranteed to private citizens rather than a right restricted to "well regulated militia[s]". The Justices asserted that sensible restrictions on the right to bear arms are constitutional, however, an outright ban on a specific type of firearm, in this case handguns, was in fact unconstitutional. The Heller decision is limited because it only applies to federal enclaves such as the District of Columbia. In 2010, the SCOTUS expanded Heller in McDonald v. Chicago incorporating the 2nd Amendment through the 14th Amendment as applying to local and state laws. Various Circuit Courts have upheld their local and state laws using intermediate scrutiny. The correct standard is strict scrutiny review for all "fundamental" and "individual" rights. On June 28, 2010, the U.S. Supreme Court struck down the handgun ban enacted by the city of Chicago, Illinois, in McDonald v. Chicago, effectively extending the Heller decision to states and local governments nationwide. Banning handguns in any jurisdiction has the effect of rendering invalid any licensed individual's right to carry concealed in that area except for federally exempted retired and current law enforcement officers and other government employees acting in the discharge of their official duties. In 2022, the Supreme Court ruled in New York State Rifle & Pistol Association, Inc. v. Bruen, that the Second Amendment does protect "an individual's right to carry a handgun for self-defense outside the home." The case struck down New York's strict law requiring people to show "proper cause" in order to get a concealed weapons permit, and could affect similar laws in other states such as California, Hawaii, Maryland, Massachusetts, New Jersey, and Rhode Island. Shortly after the Supreme Court ruling, the attorney generals of each of California, Hawaii (concealed carry licenses only), Maryland, Massachusetts, New Jersey, and Rhode Island (permits issued by municipalities only) issued guidance that their "proper cause" or similar requirements would no longer be enforced. Legal liability Even when self-defense is justified, there can be serious civil or criminal liabilities related to self-defense when a concealed carry permit holder brandishes or fires