constitutional longer for greater protection than the federal constitution is sure that this time of the drafting of the only constitutional language differed from the federal constitution to ensure that it recognize an individual right ownership deed the protections afforded by court under the nd amendment have far outstripped those afforded by this or under illinois constitution prior to that time on this part of held in your comprehensive people ask that this state claims it needs to know who brown is but her long gun never leaves her home and she's not disqualified from possessing the long gun there is nothing for the state to determine this is an argument dressed statement first the state doesn't know whether she is eligible until it applies licenses and that's the way it always is used and there is a longstanding history of there are no public safety concerns involved with a firearm that is kept in one's home on through suicide accident the master violence much of the gun violence in the state does  to the broader point that the state doesn't actually have any evidence or data to support any of the assertions that it's make this is what the state did brown is a wide citizen except for the license that only ensures compliance with itself she's not a disqualified person under federal law or state law from possessing a firearm there is no allegation that she is mentally ill or a felon just as per your right there is no allegation really there she was actually in possession of the firearm at the time she was specifically about her so are your arguments here as applied i situational challenges or facial constitutional challenges because obviously the very different analysis of court we have to report what is specifically  each one of these points is that as apply or facial justice i think that it is a it's an as applied challenge to vivian brown but it cannot be denied that in the wording of the circuit  every circumstance but i am arguing that it is that we still little broader as a five challenge because there are people and ms brown's shoes that the circuit court seemed to be addressing to look at it any more specific i'm sorry the less the so than vivian brown to rule in this case i think maybe what the when i say it sort of maybe a broader as long standing regulations apply to a handguns or be african americans indians and other ago nd amendment case that was the only one pre holiday or that kept getting cited but the fact is that nobody showed up to argue for the defense and no one brief got anything on behalf of the defense so it was really no defense in that case on the issue of long guns there was no there was no case made in our three that's why but in heller to the court pointed out that it is not on standing and they are in fact no are you are hearing that there is a difference in analysis whether it's a handgun or a long gun i am just as harmon i'm doing it for two reasons one because i'm not here on behalf of vivian ground brown to try and have won the state of virginia went so far as do you buy one for her citizens who didn't care for me if you go back then too as we're supposed to be doing and long guns not only were allowed and you didn't have to get a license to add on it was mandatory and the reason for this besides protection from bears and indians and the british and and marauders was a recognition as noted in howler that the nd amendment the the same to the home is what this case is about this is a narrow case it doesn't involve me and guns it doesn't involve the sale or purchase of handguns w you would still not be able to do it we're not challenging the requirement of having a foid card to purchase or sop we're not challenging any issues with regard to the carrying of firearms  which by the way the difference between long guns and handguns handguns you are allowed to carry concealed in public course with concealed carry license long guns you are not the if you have a long gun in your home it's not allowed to leave your home you break it down and you can transport it somewhere legal but if it's in a workable state it's not allowed to leave your home and that goes to the broader issue i think of page twelve of my brief which is if the on gun is by someone who is not federally prohibited from having one in state mirrors and it's just a long gun for protection as is the most elevated right in the nd amendment's then there is nothing for the state to determine clear that it's not even if they are not is that your honor i suppose for examples of facial challenge because they are that the applies to everybody here is why are we talking about hypotheticals you know he has a wide challenge that has nothing to do with your point i'll give you one any illinois resident with a firearm in the house who is not always carrying their the position of your clients i think that the court can affirm the sort circuit court and rule and in brown's paper without it but the circuit court certainly felt that perhaps and perhaps in arguing the end finding that he stated used its police power under article one section twenty two of the illinois constitution i think the truth is i am not sure exactly what what the circuit court reason for adding that n but it certainly was important to the circuit cour of course this is the insight into just making we're thinking about how to write an opinion in this case if we say this is a facial challenge the paragraphs or go in a certain way if this isn't as applied challenge we're going to be different kinds of paragraphs we need to know what is this case what is the issue in this case so that we can determine how to make an analysis and then each keep switching up and back up and back and that's not helpful i apologize jus you order i would ask is that as applied to vivian brown a law abiding person who is not disqualified from possessing a firearm they had it is unconstitutional to require her to possess a ford car to possess a long gun in her home for self defense and that as applied to her and those circumstances that for thirty i'll see a sixty five slash two and slash four by late the nd amendment and article one section twenty two dollars of the illinois constitution the fact is that in any criminal case there is usually one criminal defendant but a ruling in that defendant's favor could have far reaching implications for other defendants in other cases i think that's what the circuit or it was getting at that's what i'm getting at but in terms of writing an opinion affirming the circuit  what i said there are those two sentences some of them which is why justice thomas when you sad you asked me the question and the st part of it was in my saying that it's unconstitutional as vivian brown to have a long gun in her own result offense purposes without a white part as i say yes when at the and you asked any person should be able to have a long gun in their home for self defen that might be the a fact for some other person but it's not what i'm asking in this case i'm asking you to affirm the decision in favor of vivian brown so slash to a one as that as applied to defended and you mentioned i think section four swell i thought i heard mention section four but it's limited the written order to sixty five slash t person that does not have any sort of disqualifier they are concerned about felons and the mentally ill federal law also prohibits illegal aliens unlawful drug users those who are announced their citizenship  there's there's the mastic violence misdemeanor it's on any one of those the state would be allowed to say you can't have any kind of firearm but if you don't meet one of those  felon if his plight had mental health issues and went through a litany of situations in which his client would not under the circumstances you will to keep a a health issue might be somewhat broader than the actual construction of the act but but that's exactly the point of the licensing scheme is that it is a prophylactic measure that the state uses to determine whether someone falls into one of