Not necessarily so. More information on US vs Skoien here - http://illinoiscarry.com/forum/index.php?showtopic=20222 Short of The SCOTUS setting the level of scrutiny in McDonald vs. Chicago, strict scrutiny will be used in the 7th circuit when addressing the "core" Second Amendment issue of "self defense." Off the top of my head, carry challenges have already been filed in DC, California (two that I know of) and the SC of NY or NJ (I can't remember) just denied hearing a case. I have pretty good suspicion that if a challenge in the 7th circuit has not already been written, there will be one ready to go post McDonald. On a side note, where are Daley and Madigan going to get the $$$ to fight any of this. The handwriting is on the wall for McDonald as it is not a question of "if," but of "how" to incorporate the Second. The flagship "Chicago" is sinking fast in a big sea of taxpayer unrest and blatant corruption.