"However, outright bans on acquiring, possessing and carrying any and all types of firearms in Illinois, the District of Columbia and in various cities and counties (notably Chicago and San Francisco) have been struck down, failing to survive intermediate scrutiny where the courts determined that the government overreached in furthering its interest in public safety by completely banning private citizens from obtaining or possessing firearms or carrying firearms in public.The Supreme Court has yet to clarify the exact level of scrutiny to be applied to gun control laws, though in its decision in "D.C. v. Heller", the Court identified a broad category of laws deemed presumptively constitutional.