Whether the Second and Fourteenth Amendments allow a criminal ordinance that prohibits mere possession of firearms on an entire poorly-delineated university campus, except by permission of a single government official with unfettered discretion, which is granted only for 'extraordinary circumstances'

The University of Michigan prohibits possession of firearms on “all property owned, leased, or otherwise controlled” by the University. The ordinance, Article X, imposes criminal sanctions for firearm possession, including firearms carried openly, or concealed with a valid state license. It applies equally whether the individual is a student, employee, visitor, or patient at its hospital, allowing only for lawful firearms within a vehicle transiting campus on one of its public roads, or with permission granted by the university’s chief law enforcement officer, who is given unfettered discretion. No evidentiary record has been established. All appeals have been from the trial court’s grant of summary disposition to the university. This petition is brought based on violations of the U.S. Constitution’s Second and Fourteenth Amendments in light of state courts’ misapplication of Bruen and other cases. The Michigan Supreme Court let stand the Michigan Court of Appeals holding that the university need not comply with Bruen regarding history and tradition analysis by finding that the entire university is a “school” and therefore a “sensitive place” where the Second Amendment does not apply. This petition allows this Court to reaffirm Bruen ’s framework, clarify the limits of “sensitive places,” and preserve the Second Amendment’s guarantee of selfdefense in public spaces. The question presented is: Whether the Second and Fourteenth Amendments allow a criminal ordinance that prohibits mere possession ii of firearms on an entire poorly-delineated university campus, except by permission of a single government official with unfettered discretion, which is granted only for “extraordinary circumstances.”