#16: Gun Control On University & College Campuses

Table of Contents:

Gun Control On University & College Campuses
Campus Gun Control On College Campuses In the Wake of US Supreme Court Decisions
The Move Down From the Court Onto the Campus
What Can Universities Do to Enact Campus Gun Control Policies?
What Did The Supreme Court Do in Heller and McDonald?
The State of Concealed and Open Carry Gun Laws
Battle Lines Drawn
The Second Amendment Goes To College
Guns In Classrooms
Arizona Gun Laws and Universities
Campus Carry
Loose Laws = More Guns
Armed Campuses
Ready, Fire, Aim: The College Campus Gun Fight

Gun Control On University & College Campuses

Congress and state legislatures are assumed by most people to regulate guns. Some regulate more than others do. Some deregulate when pushed by gun rights groups who make political donations. However, universities and colleges have internal rules, regulations and campus safety protocols that control guns on school property. University presidents and provosts have always known that guns on campus in the wrong hands, at the wrong time, for the wrong reason are inherently unsafe. Guns on campus in the hands of campus police or 911 responders are always welcome. Guns in the hands of active shooters causing mayhem and bloodshed on campus are the antithesis of higher education. Mostly, colleges and universities want safety rules and protocols that tightly restrict how and when guns can be brought on campus.

Universities and colleges have historically prohibited students, faculty and visitors from bringing guns into buildings, arenas, parks, playgrounds, and sports facilities. Many had exceptions for locked glove boxes in parking lots. Gun control regulations were reasonable, rarely challenged, and expected by families and visitors. Colleges and universities were gun free zones before District of Columbia v. Heller in 2008.

Campus Gun Control On College Campuses In the Wake of US Supreme Court Decisions

Controlling guns on campuses went into a tailspin when guns found favor in US Supreme Court. “From the Constitution’s ratification in 1791 until the 2008 District of Columbia v. Heller decision, the Supreme Court had never held that a statute violated the Second Amendment. In invalidating Washington, D.C.’s extensive gun control prohibitions, which extended into the home, the Court declared that the Second Amendment protects citizens’ right to keep and bear arms in the home for the purpose of self-defense, so long as the weapon was of the kind used for such purposes at the founding. Moreover, in contrast to precedents going back to the nineteenth century, the Court stated that this right was independent of any militia service by the gun user.

In 2010 in McDonald v. City of Chicago, the Court declared that the Second Amendment was incorporated into the Fourteenth Amendment’s Due Process Clause and therefore enforceable against the states. This meant that as of 2010 a new protection was incorporated into the Bill of Rights, and the Second Amendment joined its constitutional cousins, including, for example, the First Amendment Free Speech and Religion Clauses, as rights limiting states’ power.”[1]

The Move Down From the Court Onto the Campus

Neither Heller nor the McDonald cases involved gun control by universities or colleges. The Court aimed its judicial guns at Congress and state legislatures. Lower courts followed suit, taking up the downstream issue of gun control on college campuses by colleges or universities via their governing bodies and student safety protocols. The first two cases were University of Utah v. Shurtleff, decided in 2006, and DiGiacinto v. The Rector and Visitors of George Mason University, decided in 2011. “These are the only two state supreme court cases to date that have examined the authority of state colleges and universities to establish campus gun regulations under state constitutional provisions and statutory enactments. [However], a case from an intermediate appellate court in Colorado is also considered closely. That case, Students for Concealed Carry on Campus, LLC v. the Regents of the University of Colorado, examined similar questions.”[2]

What Can Universities Do to Enact Campus Gun Control Policies?

The challenge is keeping campuses safe now that our highest court, the federal Congress, and some state legislatures have knocked down safety barriers once used to keep students and faculty safe. Federal institutions and state higher education entities are conflicted by constitutional and statutory constraints that encourage open carry, concealed carry, and guns with red, white, and blue ribbons wrapped around barrels. How can higher education create a regulatory policy consistent with acting autonomously in fashioning campus gun control policies? Governing bodies must follow the law but are obligated to derive principles that fill policy goals, not just America’s love affair with guns. Doing both will require governing bodies  to remaining faithful to citizens’ individual Second Amendment rights to “keep and bear arms,” and state limitations on campus institutional power. There will be areas of division and areas of commonality. The colleges have unique obligations to the higher ed community to enact and maintain campus safety. If left to partisan politics campuses will default on their obligations to students, families and faculty.

What Did The Supreme Court Do in Heller and McDonald?

The Second Amendment states: “A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.” In Heller, Justice Antonin Scalia, writing for the majority declared that the Second Amendment protects an individual’s right to possess a firearm, unconnected with militia service, and the right to use firearms for traditionally lawful purposes, including self-defense, within the home.

Heller declared unconstitutional a nearly 35-year-old ordinance promulgated by the District of Columbia that prohibited private ownership or possession of handguns. Until Heller, the Supreme Court had never held that a law violated the Second Amendment. To the exact opposite, every Supreme Court until Heller had concluded that the Second Amendment only protected the right to have firearms solely for militia service.

What made Heller different is a “status” that made the gun culture believe it could expand gun rights to the states, not just the federal government. Because the District of Columbia is a part of the federal government, Heller left open whether the Second Amendment could be applied against states and localities. Two years later, McDonald answered Heller’s unresolved question.

In McDonald v. The City of Chicago, the Supreme Court held that the Fourteenth Amendment incorporates the Second Amendment right, recognized in Heller, to keep and bear arms for self-defense. The vast majority of firearm regulations exist at the state and local level. Applying the Second Amendment’s new application to individuals made it possible to also apply it to states rather than just limit it to the federal government.

It was the thrill of a lifetime for gun enthusiasts and conservative legislatures. “According to the McDonald Court, the modern view is that the Fourteenth Amendment selectively incorporates particular rights contained in the first eight Amendments under standards that have evolved over time.”[3]

At the surface level, the McDonald case only declared the right to keep and bear arms in a person’s home. But the court also said, “Under Heller, the need for defense of self, family, and property is most acute in the home, and handguns are ‘the most preferred firearm in the nation to keep and use for protection of one’s home and family. . . This is what led the Heller Court to conclude that citizens must be permitted “to use [handguns] for the core lawful purpose of self-defense.”

The combination of Heller and McDonald clarifies the Court’s establishment of an individual right to keep and bear arms for self-defense. That path led directly to the momentous change in tying self-defense to gun rights—the stand your ground movement. With Heller and McDonald at your back, you could shoot knowing that if you said it was self-defense, you didn’t have to prove it—the prosecution had to disprove it.
The State of Concealed and Open Carry Gun Laws

In 2008, “Twenty-six states and the District of Columbia banned concealed weapons on college and university property and twenty-three states allow individual campuses to decide. Until 2011, Utah stood alone in allowing citizens with concealed weapon permits to carry their weapons on campus. In 2010, Kansas and Mississippi passed laws that allow concealed weapon permit holders to carry loaded, concealed firearms in or on the grounds of elementary and secondary schools. The Kansas statute affects public and private K-12 school settings and allows permit holders to carry firearms at school-sponsored activities and events, while the Mississippi provision allows permit holders to carry in K-12 buildings and at college, professional and K-12 athletic events, among other settings. The Mississippi provision allows permit holders to carry in K-12 buildings, and at college, professional and K-12 athletic events, among other settings.”[4]

Since then, sixteen additional states have enacted pro-gun legislation aimed at arming campuses: Arizona, Arkansas, Colorado, Florida, Georgia, Kansas, Michigan, Mississippi, Nebraska, New Hampshire, New Mexico, Oklahoma, Tennessee, Texas, Virginia, and West Virginia. The aim is not at students or faculty. It lines out colleges and universities by preventing them from exercising governing authority. “They are of two types: (1) prohibitive, that is, the bill states expressly that colleges and universities may not regulate firearms on campus property, and (2) affirmative, that is, expressly allowing concealed carry licensees to carry firearms on college or university property. Although legislation permitting open-carry of weapons has been promoted recently in a few states, including Arizona, Arkansas, Oklahoma, Texas, and Utah, no legislature to date has authorized such provisions on college or university campuses.”[5]

Battle Lines Drawn

Given Heller and McDonald’s fault lines in making guns a Second Amendment privilege for ordinary citizens rather than the old view about just militias and home defense, colleges universities scrambled for high ground and safe havens. They evaluated the concept of autonomy on public colleges to regulate firearms on public ground independent of state oversight. Historically, public colleges held preemptive status vis-à-vis state legislatures on campus safety.

Arguably the first battle line was drawn in Utah. In University of Utah v. Shurtleff,[6] The University contended that it had the right to regulate firearms on its campus under Utah Const. art. X, § 4. The district court agreed, and the Attorney General sought review. Meanwhile, Utah Code Ann. § 63-98-102(5) was enacted. The supreme court determined that the University was subject to § 63-98-102(5). The University’s policy was contractual, not legislative, in nature; therefore, it did not violate the constitutional directive of Utah Const. art. I, § 6. Utah Const. art. X, § 4 and prior pronouncements on university governance compelled the conclusion that the University was subject to legislative control, and therefore could not enforce its firearms policy in contravention of state law.

The Utah constitution recognized “the individual right of the people to keep and bear arms [which] explicitly forecloses the state’s ability to infringe on that right. Put differently, even though the Utah Legislature possesses the state’s whole lawmaking power, it cannot use that power to infringe on the individual right to keep and bear arms. While the Utah Legislature cannot infringe on the individual right to keep and bear arms, it may define the lawful use of arms. By definition, then, a legislative act defining the lawful use of arms does not “infringe” upon the individual right to bear arms. The distinction between defining and infringing is borne out in numerous cases upholding legislative acts that ostensibly burden the right to bear arms.”[7]

The second pivotal case in the competition between governing bodies and state legislatures was DiGiacinto v. Rector & Visitors of George Mason University.[8] George Mason is a public university owned by the Commonwealth of Virginia. In evaluating gun rights on a public campus the Virginia Supreme Court said, “Unlike a public street or park, a university traditionally has not been open to the general public, but instead is an institute of higher learning that is devoted to its mission of public education. Moreover, parents who send their children to a university have a reasonable expectation that the university will maintain a campus free of foreseeable harm. Recognizing the sensitivity of the university environment, the General Assembly established a corporate body composed of the board of visitors of George Mason University (GMU) for the purpose of entrusting to that board the power to direct GMU’s affairs. . . Although the real estate and personal property comprising GMU is property of the Commonwealth of Virginia, the General Assembly has provided that that property shall be transferred to and be known and taken as standing in the name and under the control of the rector and visitors of George Mason University. . . Among the board of visitors’ powers is to control and expend the university funds. . . The board of visitors is also tasked with safeguarding GMU’s property and the people who use it by making all needful rules and regulations concerning GMU. Such necessary rules and regulations include policies that promote safety on GMU’s campus.”[9]

At issue was the constitutionality of a regulation that restricted the possession or carrying of weapons on campus by individuals other than police officers. It did not impose a total ban of weapons on campus. Mr. DiGiacinto was not a student or employee of GMU. “He visits and utilizes the university’s resources, including its libraries. He desires to exercise his right to carry a firearm not only onto the GMU campus but also into the buildings and at events. . . He argued in his complaint that the regulation violated his constitutional right to carry a firearm, that GMU lacks statutory authority to regulate firearms, and that the regulation conflicts with state law.”[10]

The university responded, “The right to keep and bear arms is not an absolute right. It contends that, as recognized in Heller, the Second Amendment does not prevent the government from prohibiting firearms in sensitive places, which includes GMU’s university buildings and widely attended university events. GMU further argued that [the regulation] is narrowly tailored because it allows individuals to lawfully carry firearms on the open grounds of GMU’s campus.”[11] Mr. DiGiacinto lost at the lower court and in the Virginia Supreme Court.

The court held that because GMU was a public school, it was a “sensitive place under the law.” That allowed it to promulgate a regulation restricting the possession or carrying of weapons in its facilities or at university events by individuals other than police officers. The regulation did not impose a total ban of weapons on campus. Rather, the regulation was tailored, restricting weapons only where people congregate and were most vulnerable, inside campus buildings and at campus events. Individuals may still carry or possess weapons on the open grounds of GMU, and in other places on campus not enumerated in the regulation.”

The Second Amendment Goes To College

The subtitle is an apt metaphor for higher education. “Historically, college campuses have served as forums for war protests, academic experimentation, and the free exchange of ideas. Although demonstrations like those in the 1960s do not seem to be the primary method of political protest among students anymore, college campuses are inherently politically charged places used for the expression of many diverse opinions.”[12]

Besides being politically charged places, they are sensitive places where students and faculty gather to bring awareness to particular causes. Gun rights, control, safety, violence and culture are causes on all American campuses. Little did anyone know that courts could or would debate “gun-free zones” on colleges so students would feel safe to express pro or con views? Expressions about guns are always fraught when guns are welcome at the table or in the classroom.
The Heller and McDonald decisions did not engage at the college level. Academic freedom didn’t conflict with gun rights freedom. But once gun rights activists move from the courtroom to the classroom, academic freedom is at risk.

“Colleges and universities also have a compelling government interest in ensuring academic freedom and supporting the free exchange of ideas between their students and faculty. Although the effect of guns on campus with respect to this interest has not yet been subject to statistical or sociological studies, there is evidence that the presence of guns may intimidate students from expressing their ideas in the classroom . . . The top priority of colleges and universities is to provide an educational learning environment where academic freedom is celebrated and the exchange of ideas may flow freely. In 1957, Justice Frankfurter declared, ‘It is the business of a university to provide that atmosphere which is most conducive to speculation, experiment, and creation.’ Overwhelmingly, college and university administrators agree that guns on campus would compromise the educational enterprise necessary for the free exchange of ideas among students and faculty. The concept of academic freedom, which has been enshrined within the First Amendment, necessarily restricts state legislatures from interfering with policy choices made by public colleges and universities.”[13]

Guns In Classrooms

Constitutional rights exist. Guns exist. But do they coexist? Consider these questions. Should college students be allowed to carry guns to their classes? Should they be allowed to possess firearms in dormitory rooms or other university housing? What about individuals merely visiting or passing through campus? Neither Heller nor McDonald stands as permission to carry in these environments. The Georgetown Journal of Law and Public Policy posed and answered similar questions in 2016. “Arguments based on historical precedent or empirical studies will provide no clear answers for courts in Second Amendment cases about university restrictions on guns. The application of the Second Amendment to universities therefore will ultimately turn on the extent to which courts exercise restraint and defer to political, legislative, and administrative choices rather than trumping those forms of decision-making with vigorous judicial protection and expansion of rights. Given the value in allowing educational institutions to make their own decisions about policies shaping the academic environment, as well as the benefits of allowing schools to experiment with a variety of approaches to difficult policy issues, judges would be wise to take a deferential approach and not aggressively impose the Second Amendment in university settings.”[14]

Arizona Gun Laws and Universities

All three Arizona public universities prohibit guns on campus, with one relevant exception. They follow state law, which permits adults to store firearms in locked vehicles if the weapon is not visible from the outside. Otherwise, Arizona Board of Regents Policies 5-302 and 5-303 prohibit weapons on Arizona campuses.[15]

As expected, the Steven Jones shooting on the NAU campus in October 2015 stirred Republican legislators at the state level to take another crack at expanding gun rights in Arizona by introducing another “gun rights” bill in 2016 at the Arizona legislature. Rep. Sonny Borrelli (R-Bullhead City) introduced HB 2072. Had it passed, it would have allowed students and faculty at all three public universities, colleges, and community colleges to carry a concealed weapon on campus. The bill would have required a permit issued by the Arizona Department of Public Safety. Rep. Borelli said, “A conversation must be started about the failed university and college policies that don’t allow faculty or students to defend themselves that is permitted by the state and that is their right under both U.S. and Arizona Constitutions.”[16]

Presumably, if passed the bill would have anticipated a different outcome at NAU on the night of October 9, 2015. Instead of just Steven Jones carrying his Glock .40 caliber, maybe the four students he shot could also have been armed. Or maybe a student not shot, but standing close by could have opened fire on Jones. Instead of a single shooter, there could have been dozens. More guns—more dead. That presumably is covered by the both the US and the Arizona Constitutions.

The Arizona Board of Regents vote on January 20, 2016, “took a stand against a bill that would allow students to carry concealed weapons on campuses statewide, but expressed interest in a program that might allow trained employees to carry guns on school grounds. The regents voted Wednesday to oppose House Bill 2072, which would allow guns to be carried on college campuses. They also opposed HB 2338, which would allow concealed weapons to be carried on the streets and roads at educational institutions.”[17]

HB 2338 does not mention guns and is not, on its face, a gun rights bill. It was a companion bill to HB 2072. Its title announces its function: “Interference With or Disruption of an Educational Institution.”[18] It would have prohibited “[i]ntentionally, knowingly or recklessly interfering with or disrupting the normal operations of an educational institution by either: (a) Threatening to cause physical injury to any employee or student of an educational institution or any person on the property of an educational institution . . . Threatening to cause damage to any educational institution . . . entering or remaining on the property of any educational institution for the purpose of interfering with the lawful use of the property or in any manner as to deny or interfere with the lawful use of the property by others . . .”[19]

ABOR’s concern was clearly stated by Vice Chairman Greg Patterson: “My fundamental concern with both bills is this is our jurisdiction.” The Arizona Board of Regents was created under Article XI, § 2 of the Arizona Constitution. “The general conduct and supervision of the public school system shall be vested in … such governing boards for the State institutions as may be provided by law. Article XI, § 5 establishes the Board. The Board is a free-standing body corporate.”[20]

Consistent with the national SYG experiment in 2017, Arkansas and Georgia passed legislation to allow students and faculty to carry guns on college campuses. From 2015 to 2020, campus safety legislation has been passed, rejected, and debated in almost every state. “At least 19 states introduced legislation to allow concealed carry on campus in some regard. . . Tennessee passed a bill in 2016, which permits higher education faculty to carry handguns after notifying local law enforcement. In 2015, Texas became the eighth state to allow concealed carry weapons on college campuses. In December 2016, Governor Kasich of Ohio signed into law SB 199 which lifts the ban on firearms on college campuses and leaves the decision to individual institutions.”[21]

Campus Carry

Who would have ever thought such a catchy phrase would become a reality on American college and university campuses? Madame Wiki says, “Campus carry in the United States refers to the possession of firearms on college or university campuses in the United States. Each state has its own discretion on laws concerning campus carry.”[22]

A distinction must be drawn in modern gun culture vernacular. Open carry is as the word says—open—you can see the gun, slung, holstered, but not brandished. Conceal carry is as the word implies—stealthy, invisible but for the bulge, but close at hand if you take my drift.

As of summer 2020, eleven states changed their laws to permit concealed carry on campus in some form; Arkansas, Colorado, Georgia, Idaho, Kansas, Mississippi, Oregon, Tennessee, Texas, Utah and Wisconsin. Additionally some colleges in Virginia and Ohio voluntarily allow concealed carry. Sixteen states prohibit concealed carry on campus by law. Twenty-three states allow colleges and universities to make their own rules against campus carry. The data points are excerpted from a website called “Students For Concealed Carry.” Their reason raison d’être is, “We believe students, faculty and members of the community with concealed handgun licenses should have the same right to self-defense on campus that they enjoy virtually everywhere else.”[23] Said differently, more guns on campus are better than no guns on campus. If the OK Corral was good enough for Tombstone, it’s good enough for college kids in Tucson, Phoenix, and Flagstaff.

Loose Laws = More Guns

In summer 2021, the Center For American Progress, identified four ways the federal government could improve college campus safety in states where lax gun laws politically prevail.[24]

First, ban guns from college campuses. The Gun-Free School Zones Act of 1990 bans guns on public or private K-12 school property, unless carried by law enforcement officers or by someone during an approved school program. However, people with licenses to carry can also bring firearms on school grounds, if state laws do not prohibit them—a dangerous loophole that makes schools less safe. Congress should extend the federal gun-free zones to include higher education institutions while also closing the loophole. This change in federal law would set the floor for campus safety standards that states can build on to implement even stronger protections.

Second, add policy disclosures to the “Jeanne Clery Disclosure of Campus Policy and Campus Crime Statistics Act.”[25] In states with campus carry laws, institutions should have to publish detailed information about where guns can be carried. Although campus carry laws typically set parameters on where people can and cannot carry guns, it is up to institutions to identify these spaces on their campuses.

Third, improve crime statistics. To understand the scope of campus gun violence, better statistics are needed than what is required under the Clery Act. According to guidance from the Department of Education, institutions track when a person is arrested or referred to a campus official for disciplinary action related to a weapons law violation, which includes not just possession and use of firearms but also knives, explosives, and other deadly weapons.

Fourth, study crime and offer guidance. The U.S. Department of Education should monitor the landscape of state campus carry laws and carefully study its own campus crime statistics. It should also update its 2010 report written with the FBI and the U.S. Secret Service—“Campus Attacks: Targeted Violence Affecting Institutions of Higher Education”—with special attention to crimes committed with firearms in order to learn how to prevent campus shootings. Second, the department should partner with the U.S. Department of Justice to study and share evidence-based strategies for reducing gun violence in both campus carry and non-campus carry states. Last, the Education Department should offer technical guidance to institutions that seek to implement such strategies or other policy changes toward preventing gun crimes.

Armed Campuses

At the turn of the last century, the phrase “armed campuses” would have mystified everyone. Except for the official military academies, there were no guns on college campuses, concealed or otherwise. Even now, the vast majority of the 4,400 colleges and universities in the United States prohibit the carrying of firearms on their campuses. These gun-free policies have helped to make our post-secondary education institutions some of the safest places in the country. [26]“For example, a 2001 U.S. Department of Education study found that the overall homicide rate at post-secondary education institutions was 0.07 per 100,000 students in 1999. By comparison, the criminal homicide rate in the United States as a whole was 5.7 per 100,000 persons overall in 1999, and 14.1 per 100,000 for persons ages 17 to 29. A Department of Justice study found that 93% of violent crimes that victimize college students occur off campus.”[27]

Ready, Fire, Aim: The College Campus Gun Fight

Panty raids, fraternity spats, fistfights, logomachy, tussles, donnybrooks, classroom tropes, and sorority tiffs were to colleges what guns are now to conservative legislatures. We should not have to vote at gunpoint. Colleges should gun-free zones. Legislators should be urging college students to aim before they shoot. Conservative views see guns as essential to personal freedom. Progressive minds see guns as instruments for mayhem and violence. Both sides debate gun control proposals as pitched battles. At the fringes of both sides, the notion that life, limb, liberty and justice are at stake rise up as battle calls to unsheathe sabers. Except that the sabers these days are made by Block.

Mark Twain knew something about guns in 1882. But he may have had the 21St Century in mind when he famously said, “Don’t meddle with old unloaded firearms. They are the most deadly and unerring things that have ever been created by man. You don’t have to take any pains at all with them; you don’t have to have a rest, you don’t have to have any sights on the gun, you don’t have to take aim, even.”

Some conservative legislators are meddling with old firearm notions—they are not taking aim. They stand their ground when they shoot first; only then do they take aim. Sorry professor, I didn’t mean to shoot you. I forgot to take aim.[28]

[1] Lewis M. Wasserman, Law Review Article. “Gun Control On College and University Campuses In the Wake of District of Columbia and McDonald v. City of Chicago.” 19 Va. J. Soc. Pol’y & L., Fall 2011

[2] Ibid.

[3] Ibid.

[4] Ibid. at 4.

[5] Ibid.

[6] 144 P.3d 1109 (2006).

[7] Ibid at

[8] 704 S.E.2d 365 (2011)

[9] Ibid at note 8.

[10] Ibid at note 1.

[11] Ibid.

[12] Joan H. Mill, 35 Seattle U. L. Rev. 235 (Fall 2011).

[13] Ibid at page 260 to 263.

[14] Reporter 14 Allen Rostron, Geo. J.L. & Pub. Pol’y 245. Winter 2016

[15] Unauthorized use, possession, or storage of any weapon, dangerous instrument, explosive device, torch, device with open flames, or fireworks on the university campus or at a university-sponsored activity except that subject to A.R.S. § 12-781 and other applicable law, a person may lawfully transport or lawfully store a firearm that is both (1) in the person’s locked and privately owned motor vehicle or in a locked compartment on the person’s privately owned motorcycle, and (2) not visible from the outside of the motor vehicle or motorcycle, although the board or a university may require that vehicles transporting or storing firearms be parked in alternative parking as described in A.R.S. § 12-781. The possession or use for self-defense of personal safety devices are not prohibited by this section. ABOR Policy Manual, Policy Number 5-303. Policy Revision Dates: 2/2020, 6/18, 2/18, 9/09, 9/83, 5/83 Page 1. February 2020.

[16] Anne Ryman and Alia Beard Rau, “Regents Vote to Oppose Two Gun Bills.” The Arizona Republic, January 21, 2016, page A1.

[17] Anne Ryman and Alia Beard Rau, “Regents Vote to Oppose Two Gun Bills.” The Arizona Republic, January 21, 2016, page A1.

[18] https://www.azleg.gov/legtext/52leg/2r/bills/hb2338p.pdf.

[19] Ibid.

[20] https://repository.asu.edu/attachments/92611/content/WhatIsABOR_brochure.pdf.

[21] https://www.ncsl.org/research/education/guns-on-campus-overview.aspx.

[22] https://en.wikipedia.org/wiki/Campus_carry_in_the_United_States.

[23] https://concealedcampus.org/2020/07/how-many-states-allow-campus-carry/

[24] https://www.americanprogress.org/issues/education-postsecondary/news/2021/07/27/502039/4-ways-federal-government-can-improve-college-campus-safety-states-lax-gun-laws/

[25] The Clery Act requires all colleges and universities that participate in federal financial aid programs to keep and disclose information about crime on and near their respective campuses. Compliance is monitored by the United States Department of Education, which can impose civil penalties, up to $58,328[2] per violation, against institutions for each infraction and can suspend institutions from participating in federal student financial aid programs. The law is named after Jeanne Clery, a 19-year-old Lehigh University student who was raped and murdered in her campus residence hall in 1986. Her murder triggered a backlash against unreported crime on campuses across the country. https://en.wikipedia.org/wiki/Clery_Act

[26] https://www.armedcampuses.org/.

[27] Ibid.

[28] http://www.twainquotes.com/Guns.

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