How 2A Rights Link To Training

There have been so many instances that people say things
like “I don’t see anywhere in the Second Amendment where it says you can xyz.”
Xyz, of course is a stand in for any argument that someone who’s not civil
rights minded might make against what the Second Amendment means.

A crucial and important element of the exercise of our
Second Amendment right is the ability to practice and train. In order to
practice and train, we must have access to facilities and ranges to take part
in live fire exercises. Arguments in the 2019 SCOTUS NYSRPA v. City of New York case were
made about how the right to keep and bear arms, and to be able to do so
responsibly, one must have access to ranges for practice. While the case was
deemed moot by the majority of the justices, Justice Alito in his dissent
noted the following:

“And still another is
to take a gun to a range in order to gain and maintain the skill necessary to
use it responsibly. As we said in Heller, ‘ ‘to bear arms implies something
more than the mere keeping [of arms]; it
implies the learning to handle and use them in a way that makes those who keep
them ready for their efficient use
.’ ’ 554 U. S., at 617–618 (quoting T.
Cooley, Constitutional Law 271 (1880)); see also Luis v. United States, 578 U.
S. ___, ___ (2016) (THOMAS, J., concurring in judgment) (slip op., at 3) (‘The
right to keep and bear arms . . . ‘implies
a corresponding right . . . to acquire and maintain proficiency in their use’
Ezell v. Chicago, 651 F. 3d 684, 704 (CA7 2011) (‘[T]he core right wouldn’t
mean much without the training and practice that make it effective’)’“

A recent win in Pennsylvania illustrates this concept. The
situation started several years ago with suit being filed in 2018. The
particulars revolved around a zoning ordinance, which the Township of Robinson
and Zoning Officer Mark Dorsey were responsible for, and kept Plaintiffs
William Drummond and GPGC LLC from being able to operate a sportsmen’s club.
Joining Drummond and GPGC was the Second
Amendment Foundation
in this litigation. Drummond LLC v. Robinson Township had a winding and rocky road and
on October 13, 2021 a Preliminary Injunction Order was put in place. The order
spells out some of the details of the case as well as offers relief.

“The subject property
(‘Property’), known largely as the “Greater Pittsburgh Gun Club” (GPGC),
operated as a commercial gun club, with certain gaps in operation, from the mid
1960’s until January 2018. The Property consists of approximately 265 acres
situated in Robinson Township, Washington County, Pennsylvania.

William Drummond
entered into a lease with his uncle, Joseph Donald Freund, Jr., for the
265-acre parcel located at 920 King Road in Robinson Township ‘for purposes of
operating a gun club, the retail sale of firearms, and operating a shooting

On March 15, 2018, Mr.
Drummond submitted an Application for Zoning Permit, representing to the
Township that he intended to operate a Sportsman’s Club on the premises. (ECF
No. 1,


On April 9, 2018, the
Board of Supervisors enacted Ordinance 01-2018, to amend the Township’s Zoning
Ordinance in three respects:

a. A definition of ‘Sportsman’s
Club’ was added to Section 601 of the Zoning Ordinance, which provided that a
“Sportsman’s Club” is ‘[a] nonprofit entity formed for conservation of wildlife
or game, and to provide members with opportunities for hunting, fishing, or

b. Paragraph D was
added to Section 311 of the Zoning Ordinance, regulating ‘Sportsman’s Clubs,’
which provided that ‘[o]utdoor shooting activities shall be limited to pistol
range, skeet shoot, trap and skeet, and rim-fire rifles;’ and

c. ‘Section 208, Table
208(A) IBD Interchange Business Development District Table of Allowed Uses
shall be amended to reflect the zoning change set forth herein. Specifically, a
Sportsman’s Club shall no longer be allowed as a Permitted Use in an IBD
Interchange Business Development District, and shall instead only be allowed as
a Conditional Use in an IBD Interchange Business Development District.’

On April 13, 2018, Mr.
Drummond received notice that his Application for Zoning Permit had been denied,
as his application did not indicate that the GPGC was organized as a not-for
profit entity.”

Thick and weighty are the details of this case, but also
fickle. Also from the preliminary injunction Drummond received the
following good news:

“Based on the
foregoing findings of fact and conclusions of law, Plaintiffs’ Preliminary
Injunction is hereby GRANTED as follows: Defendants, their officers, agents,
servants, employees, and all persons in active concert or participation with
them who receive actual notice of the injunction are enjoined from enforcing
Robinson Township Zoning Ordinance Sections 311(D), 601, and 208, Table

While this is a Preliminary Injunction, this is still a very
large win for all Americans. The matter of townships bullying their way to a
disarmed population is one that should not proliferate. This ban through
regulation tactic needs to be stopped dead in its tracks and that’s exactly
what this order does.

SAF founder and Executive Vice President Alan M. Gottlieb
had several comments to make about this victory in a press

“’We’re happy with the
judge’s ruling because this should signal an end to Mr. Drummond’s problems
with Robinson Township,’ said SAF founder and Executive Vice President Alan M.
Gottlieb. ‘Government simply cannot use zoning restrictions to put a business
they don’t like out of business.’

‘The judge was forced
to issue the ruling after twice having the case remanded back to her by the
federal appeals court, where SAF and the other plaintiffs received favorable
rulings that the case should proceed,’ Gottlieb noted.”

More about the order:

“In her ruling, U.S.
District Court Judge Marilyn J. Horan noted, ‘Although the courts owe
‘substantial deference’ to local zoning decisions, restrictions on rights
guaranteed by the Second Amendment…must still satisfy intermediate scrutiny…At
this stage and for purposes of the Motion for Preliminary Injunction, the
Township has not provided evidence that the challenged Ordinance provisions…in
fact serve the asserted government interests of health, safety, and welfare.’

‘Gun ranges are a
necessary component in the exercise of Second Amendment rights,’ Gottlieb
observed. ‘Even Judge Horan recognized this in her ruling, where she quoted the
Supreme Court’s decision in Heller that ‘The right to bear arms ‘implies
something more than mere keeping; it implies the learning to handle and use
them; . . . it implies the right to meet for voluntary discipline in arms.’ In
essence, the township was trying to zone out the Second Amendment.’

‘This court victory is
important because it shows your Second Amendment rights don’t stop at your
front door,’ Gottlieb said. ‘It’s essential to our mission of winning firearms
freedom one lawsuit at a time.’”

Gottlieb is correct in his assertion that we’re winning
firearms freedom one lawsuit at a time. If only the anti-civil rights crowd
would smarten up and stop their shenanigans. Think about how much tax money
would be saved if the dug-in jurisdictions did not try to defend these awful
policies. Kudos! to Drummond and the Second
Amendment Foundation
for standing up for what’s right.

As for those of us that have access to facilities. Practice
and train often! Remember to sharpen those skills regularly with trusted

Also be sure to check out JM4 Tactical for your holster needs!

Stay safe out there and think before you do!

John Petrolino is a US Merchant Marine Officer, writer,
author of “Decoding
Firearms: An Easy to Read Guide on General Gun Safety & Use”
and USCCA certified
instructor, NRA certified pistol, rifle and shotgun instructor living under and
working to change New Jersey’s draconian and unconstitutional gun laws. You can
find him on the web at
on twitter at @johnpetrolino
and on instagram @jpetrolinoiii