The Supreme Court heard arguments earlier this month in a major Second Amendment case challenging New York’s restrictive framework for approving concealed carry permits.

During the arguments in New York State Rifle & Pistol Association v. Bruen, New York Solicitor General Barbara Underwood defended the fact that officials more strictly apply the discretionary framework to residents in urban areas of the state, who receive carry permits at disproportionately far lower rates than residents in more rural areas.

Underwood explained that this was a perfectly reasonable display of discretion, as residents in more densely populated urban areas enjoy a greater police presence than those in less-densely populated rural areas.

Chief Justice John Roberts cut right through Underwood’s logic, saying: “If the purpose of the Second Amendment is to allow people to protect themselves, then it’s implicated when you’re in a high-crime area. It’s not implicated when you’re out in the woods. … How many muggings take place in a forest?”

Roberts is correct: The Second Amendment is premised on the natural right of self-defense, the need for which is greatest where the risk of crime is highest.

Crime data clearly show that people are victimized outside their homes more often than inside their homes. Additionally, people in urban areas are far more likely to be victims of crime—and therefore more likely to need to defend themselves with a gun—than are people in rural areas.

And Americans routinely use guns to defend themselves successfully from crime.

Almost every major study on the issue has found that Americans use their firearms in self-defense between 500,000 and 3 million times annually, according to a 2013 report by the Centers for Disease Control and Prevention.

For this reason, The Daily Signal each month publishes an article highlighting some of the previous month’s many news stories on defensive gun use that you may have missed—or that might not have made it to the national spotlight in the first place. (Read other accounts here from 2019, 2020, and so far this year.)

The examples below represent only a small portion of the news stories on defensive gun use that we found in October. You may explore more by using The Heritage Foundation’s interactive Defensive Gun Use Database. (The Daily Signal is the multimedia news organization of The Heritage Foundation.)

• Oct. 1, Port Arthur, Texas:  When two armed persons attempted to hold up  a fast-food restaurant, a customer intervened, shooting at them with his own firearm until they fled, police said. Both would-be robbers were struck—one fatally—by the customer’s gunfire, but reports didn’t indicate that anyone else was injured.
• Oct. 5, Marcola, Oregon: Police said a woman shot a man after he strangled her and attempted to hit her with a baseball bat during a domestic dispute. The wounded man was taken to a hospital for treatment before being charged with several felonies.
• Oct. 9, Tonopah, Arizona: A homeowner told reporters that he doesn’t normally carry a gun, but was glad he did so on the day a wanted felon threatened his family. The felon had prompted an hourslong manhunt after fatally beating a sheriff’s deputy and stealing his car. The wanted man approached the homeowner and his daughters outside their residence, threatening them with a wooden knife. Law enforcement officials said the felon left but returned with a gun and exchanged fire with the homeowner, who wounded him.
• Oct. 10, Milwaukee, Wisconsin: A security camera captured the moments in which two masked gunman attacked a man and his girlfriend after they pulled into a driveway. In what police described as an attempted robbery, one of the assailants confronted the man as the second appeared to lead the woman away at gunpoint. The man retrieved a handgun from his car and shot at the attackers, who returned fire as they fled, hitting him twice.  The victim admitted he didn’t have a concealed carry permit, but Wisconsin law allows lawful owners to possess a loaded handgun in a vehicle as long as the gun is not concealed.  
• Oct. 12, Rock Hill, South Carolina: A woman used her handgun to defend herself from a would-be rapist, police said. The woman was walking down a street at night when a man grabbed her and attempted to drag her into a wooded area. She fought back, striking her attacker several times as he tried to pull her pants down. The woman was able to escape his grasp, draw her gun, and fire at her assailant until he fled, police said. Police later arrested a suspect who they said implicated himself in other recent cases of sexual assault and other crime in the area.
• Oct. 15, Spotsylvania Courthouse, Virginia: After a man called police to report being shot at while using an ATM, responding officers quickly learned that the caller instead was a convicted violent felon who had just assaulted and tried to rob a concealed carry permit holder. The permit holder drew his gun and fired at his assailant before calling police himself, investigators said. The permit holder suffered minor injuries, but his assailant was not hurt.
• Oct. 17, Lancaster, Pennsylvania: When an armed teenager opened fire during an altercation in a crowded mall, police said, a concealed carry permit holder intervened to end the threat to other shoppers. Reports indicate the armed teen shot another teen during a fist fight, then shot at least two unarmed bystanders who attempted to stop him. He also shot and wounded a female standing nearly 70 feet away. The permit holder heard the gunshots from inside a store and confronted the teen gunman, who was wrestling with another man over the gun. The teen fired at the permit holder as he approached, missing him by less than a foot, prosecutors said. The permit holder shot at the gunman three times, wounding him and then kicking away the teen’s gun. He held the teen at gunpoint until police arrived.
• Oct. 21, Superior, Nebraska: A man who recently had been fired returned to the grain elevator where he had worked and began shooting former managers and co-workers, police said. Some employees tried to barricade themselves in an office, but the gunman fired at them through the door and forced his way inside. By that time, however, another employee had retrieved a shotgun kept on-site. He fatally shot the gunman just 20 seconds after the violence began, police said. Although the gunman killed two people and wounded a third, the armed employee’s actions almost certainly saved many other lives.
• Oct. 25, Philadelphia, Pennsylvania: A resident fatally shot a man as he broke into his ex-girlfriend’s house, police said. The ex-girlfriend was not home when the man kicked the front door off its hinges, but several other residents were—including the gunowner. Police were investigating the residents’ allegations that they called 911 three times to request law enforcement assistance during the break-in and before the fatal shooting, but that dispatchers didn’t answer.
• Oct. 29, Kansas City, Missouri: After a landlord fatally stabbed a tenant for complaining that the heat in the apartment wasn’t working, an armed neighbor who heard another tenant screaming arrived and held the landlord at gunpoint until police arrived.

The reality is that, despite the best efforts of law enforcement, Americans often are left as their own first and best defense against those who would harm them.

Urban New Yorkers living in high-crime areas are not rendered any safer just because more law enforcement officers hypothetically are available to show up after a crime has been committed against them.

They are rendered safer when they and other ordinary, law-abiding citizens are allowed to defend themselves and others—whether in their own homes or in public, in secluded areas or crowded shopping malls.

It’s time for New York to move away from onerous, arbitrary restrictions on Americans’ fundamental right to bear arms for self-defense, and finally allow all law-abiding residents the option of exercising it.

This piece originally appeared in The Daily Signal