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What we are now seeing is this 2A two-step, in action. The recent decision in Georgia Carry.org v. Georgia is the best example I can give.
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Actually, that case is an example of the sort of litigation we don't need to be bringing. There have been several cases (
US v. Williams being notable) brought in the wake of Heller that were premature, ill-argued, or with unsympathetic plaintiffs.
We need to pick fights we can win. Every fight we lose has the potential to set a precedent, and bad precedents make for bad law.
Frankly, I know of no religion (with the possible exception of Sikhism, which is not on the table here) that
requires the carry of weapons as part of services. As such, the plaintiff's attempt to tie the church ban to the free-exercise clause comes off as really weird, and not very sound strategically.
All we're left with from this challenge is a finding that churches are "sensitive places" under the
Heller dicta, and that bans on carry there are constitutional.