The Seventh Circuit Court of Appeals has upheld Illinois prohibition on carrying firearms aboard public transportation, reinforcing the states ability to regulate guns in crowded and confined environments. The decision, issued September 2, 2025, reverses a 2024 lower court ruling that had sided with plaintiffs who argued the ban violated the Second Amendment. The case began in 2022 when four men filed suit against a state law that forbids carrying firearms on buses and trains unless they are unloaded and secured. Illinois requires residents to obtain a firearm owners identification card before applying for a concealed carry license, but even licensed carriers are restricted from bringing guns onto public transit. In 2024, a lower court found this provision unconstitutional under the Supreme Courts 2022 decision in New York State Rifle & Pistol Association v. Bruen, which requires firearm regulations to align with the nations historical tradition. Judge Joshua Kolar, writing for the panel, rejected that conclusion. He explained that Bruens framework demands analogical reasoningcomparing modern regulations to historical traditionseven if the precise circumstances differ. While the Founders never envisioned buses and trains, Kolar wrote, the reasoning behind restrictions in sensitive places like courthouses, polling sites, and legislative chambers applies equally to modern transit systems. He emphasized that buses and trains are enclosed, crowded, and filled with people unable to easily escape in the event of gunfire, making them distinct from open public areas. Illinois Deputy Solicitor General Alex Hemmer argued that 19th-century passenger railroads, which often imposed restrictions on firearms, provide a relevant analogue. The plaintiffs attorney, John Ohlendorf, disagreed, stating that such rules were private company policies rather than government mandates and therefore not valid comparisons. He likened them to household rules, useful for private settings but not instructive for constitutional law. The panel ultimately sided with Illinois, finding that historical practice supports firearm restrictions in confined and vulnerable spaces. Kolar also compared Illinois restrictions to federal rules on air travel, which permit firearms only if unloaded, stored out of reach, and declared. In his view, both reflect a longstanding approach to mitigating risks in mass transit systems. Judges Amy St. Eve and Kenneth Ripple joined the opinion, with St. Eve noting that while the ruling reinforces sensitive-places doctrine, it should not be applied as a broad test for all Second Amendment challenges. She stressed that Bruen requires case-by-case evaluation of how and why a law burdens the right to bear arms. The ruling preserves Illinois regulatory framework, which permits licensed carry in many public places but excludes schools, courthouses, and nowfirmlypublic transit. For concealed carry holders, the practical outcome is unchanged: firearms remain prohibited on buses and trains regardless of permit status. For Illinois lawmakers, the decision affirms their authority to tailor restrictions for environments where the risks are uniquely high.