that the post-McDonald measures adopted by the City of Chicago were constitutional. The Chicago law required firearms training in a shooting range in order to obtain a gun permit, but also banned shooting ranges within the City of Chicago. The city had argued that applicants could obtain their training at gun ranges in the suburbs. The opinion noted that Chicago could not infringe Second Amendment rights on the grounds that they could be exercised elsewhere, any more than it could infringe the right to freedom of speech on the grounds that citizens could speak elsewhere. California On January 14, 2009, in Guy Montag Doe v. San Francisco Housing Authority, the San Francisco Housing Authority reached a settlement out of court with the NRA, which allows residents to possess legal firearms within a SFHA apartment building. The San Francisco lawsuit resulted in the elimination of the gun ban from the SF Housing Authority residential lease terms. Tim Larsen speaking for the Housing Authority said that they never intended to enforce its 2005 housing lease gun ban against law-abiding gun owners and have never done so. Idaho On January 10, 2014, in Morris v. U.S. Army Corps of Engineers, the District Court struck down a Corps of Engineers regulation barring possession of loaded guns in recreation areas surrounding Corps dams. The court held that tents are akin to homes, and under Heller, Second Amendment rights are protected. Legacy The decision in McDonald v. City of Chicago, which was brought in response to Heller and decided in 2010, did invalidate much of Chicago's gun purchase and registration laws, and has called into question many other state and local laws restricting purchase, possession, and carry of firearms. Justice Stevens later called the decision "unquestionably the most clearly incorrect decision that the Supreme Court announced during my tenure on the bench" and called for a Constitutional amendment overruling it". Stephen Halbrook, a lawyer and Second Amendment analyst who successfully argued three firearms-related cases before the Supreme Court, concluded the majority's opinion in Heller "relied on text, history, and tradition." Halbrook asserted that the individual right to bear arms was not an invention of gun rights activists in the preceding few decades, but was in fact a textualist interpretation confirmed by the historical context of the Second Amendment. This included the English Declaration of Rights of 1689, as well as "post-ratification commentary, antebellum judicial opinions, Reconstruction