The four Democrats on the high court kicked the case back to the trial court, while the court's three Republicans joined in dissent. Medical Marijuana Licenses are state-issued and cannot result in the denial My son was facing some possible serious consequences. The majority never explains why it is perfectly fine with the appellate court reversing the order but considers it an affront to this courts authority for the circuit court to reconsider it. The __gads cookie, set by Google, is stored under DoubleClick domain and tracks the number of times users see an advert, measures the success of the campaign and calculates its revenue. In his ruling, Judge Webb stated, "A citizen in the State of Illinois is not born with a Second Amendment . Were also offering a home delivery option as an added convenience for friends of the paper. It does not store any personal data. The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". Earlier: Illinois State Police sued over concealed carry license delays. This cookie, set by YouTube, registers a unique ID to store data on what videos from YouTube the user has seen. Thank you for your hard work and for treating me as a valued client. Tom has been our lawyer for many years now for multiple reasonsand I want tell everyone out there that not only can this man do his job well he has exceeded all expectations. I have not within the past year (preceding the date of this application) used or been addicted to any controlled substance or narcotics in violation of state or federal law. Capitol News Illinois is a nonprofit, nonpartisan news service covering state government and distributed to more than 400 newspapers statewide. ISP DIVERSITY, EQUITY, AND INCLUSION PLAN, OFFICE OF THE STATEWIDE 9-1-1 ADMINISTRATOR. SPRINGFIELD, Ill. (WTVO) A circuit court judge ruled Illinois' FOID Card is unconstitutional. Apparently seeking to prevent the Illinois Supreme Court from skirting the constitutional question raised, Webbs opinion also states explicitly that ruling the FOID card law unconstitutional is necessary to this Courts decision and it cannot rest its decision upon an alternative ground., Webb found any fee associated with exercising the core fundamental Constitutional right of armed self-defense within the confines of ones home violates the Second Amendment.. Thanks again. I have not been adjudicated by a court as a mental defective or ordered by a court, board or authorized entity to in-patient or out-patient mental health treatment. Disclaimer | Privacy Policy | Sitemap | Copyright. Peoria, Illinois and he had not been issued a currently valid FOID card or firearm concealed carry license." 5 Separate assistant public defenders were appointed to represent defendants. Justice Michael Burke who is not related to the chief justice wrote the dissent, making up 11 of the 21 pages in the Thursday order. I think that the FOID imposes a minimal burden on law-abiding citizens. Thank you so much for your help. Thus, the state appealed the rulingback to the Supreme Court, leading to the Thursday ruling in which the majority decided the lower court had no authority to reconsider the case after the Supreme Courts 2020 ruling. It is a faade. And if it is the latter, then there is no reason why the trial court could not exercise its inherent power to reconsider its own ruling. A Breakdown of Law Surrounding Bearing Weapons With a Concealed Identity. If the state decides to appeal this decision that found the FOID law unconstitutional, the appeal will be heard by Illinois Supreme Court just as the high court did in 2018 when the FOID card law was found unconstitutional by a different judge in this case. 60,370 views Apr 30, 2021 5.2K Dislike Share TheGunCollective 300K subscribers Jon Patton talks about the state of. If the order is subject to review on the merits by the appellate court, then it is subject to reconsideration on the merits by the trial court. If the right to bear arms and self-defense are truly core rights, there should be no burden on the citizenry to enjoy those rights, especially within the confines and privacy of their own homes. When officers arrived, they found a rifle beside her bed but no evidence that she had fired it. For this reason, the case against the defendant was dismissed. Mr. Glasgow is a phenomenal attorney and we would recommend him in a heartbeat to anyone needing legal help. Under section 8 of the FOID Card Act, the Department is ; authorized to deny an application for or revoke a card based on certain disqualifying Your California Privacy Rights / Privacy Policy. Brown's estranged husband reported to the police that she had fired the rifle in the house. Why a full sized 1911? The argument is, this sort of infringement is forbidden by the Second Amendment. Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services. card in order to acquire or possess a firearm. some people have waited since 2020 to get their card in the mail. Nor does the majority explain why, if this court has not considered the merits of the statutory issue, it is forcing the trial court to maintain a certain position on that issue. The state appealed directly to the Illinois Supreme Court a few months later. Well, not yet. will be forthcoming. He predicted the case will return to the high court a third time and the state Supreme Court will ultimately have to rule on the constitutionality of the state gun permit law. Anytime I called or emailed Mr. Glasgows office during the course of my case, I received immediate honest answers and understanding to the current status of my case. If the right to bear arms and self-defense are truly core rights, there should be no burden on the citizenry to enjoy those rights, especially within the confines and privacy of their own homes. Ordering the case back to the circuit court, the majority ordered a modified circuit court order that was originally entered in 2020. At issue is whether the Illinois Firearm Owners Identification Card, or FOID, is an unconstitutional infringement on a citizen's right to bear arms. the FOID Card Review Board for its timely consideration. Youtube - Track the views of embedded videos. Pritzker Announces Income Tax Filing Extension, More Than $90 Million in Small Business Aid. You dont really think those crooks in Springfield will give up their $10 a head revenue stream without a long, drawn out fight. You are the exception to the rule and take your job serious and treat your clients in a professional manner and as an asset, You listen to their concerns and work on getting them the outcome they are looking for not just whats the quickest and easiest solution. 0:45 SPRINGFIELD - In a 4-3 decision with a blistering dissent from the Republican minority, the Illinois Supreme Court declined to rule on a question of whether Illinois Firearm Owners Identification Act is unconstitutional. However, that could change based on the outcome of Anderson v. Raoul. But a circuit judge in White County threw out the charge, saying the Illinois law requiring potential gun owners to fill out a form, provide a picture ID, undergo a background check and pay a $10 fee to obtain a FOID card was unconstitutional, at least as it applied to Brown. All Rights Reserved. Plus, there is a good chance that the state will appeal the decision and the defendant mentioned above could be left in legal limbo for an extended period of time while the courts determine if the FOID act applies to her case. "The circuit court was correct that the FOID card requirement impermissibly . I am not intellectually disabled or developmentally disabled. "Whenever the court can rule on an issue without having to get into the Second Amendment constitutional issue, they will dodge, they will punt," said Todd Vandermyde, the retired, longtime Statehouse lobbyist for the National Rifle Association. He asked: Why should a license be required to exercise a Second Amendment right? With an empathetic heart, shoulder to cry on, he listens and will help you through the worst & best of times. A link to the FOID Card Review Board and its contact information In February 2018, the White County Circuit Court sided with Brown and found the FOID card law unconstitutional when applied to her case. State law requires the Illinois State Police to grant or deny a FOID card application within 30 days of receiving it. In reality, the judgment of the circuit court was not a judgment of this court that was final and conclusive on all the parties because this court declined to reach the merits of the statutory analysis and only vacated the circuit courts judgment on procedural grounds. Nobody should have to pay money to the government to exercise their Second Amendment constitutional right," Pearson said. Because they don't want to rule on it because they know what the ruling should be. Please feel free to use this letter on your website or any other promotional tool as I would highly recommend you as an attorney in any criminal case. $10.00 payable with a credit card or electronic check. Finally, someone who can make it matter, agrees. Illinois law currently requires residents seeking to . YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data. April 27, 2021 BELLEVUE, WA - An Illinois Circuit Court Judge in White County has ruled the requirement for possessing a Firearm Owner's Identification Card to possess a gun in the home is unconstitutional under the Second Amendment. We did concealed carry 2014, I think but it was as a result of a judges opinions, this may have the same effect, said Rep. Mike Zalewski (D). I have not been adjudicated as a mental defective. cannabis card or until one year after you last used cannabis, whichever is later. 0:04. In 2020, the state Supreme Court kicked the case back to the trial court on a technicality. This anonymous data helps us to better understand users' needs and customize the website accordingly. of any right or privilege. This website uses cookies to improve your experience while you navigate through the website. Burke was joined in the majority by Democrats Mary Jane Theis, P. Scott Neville Jr. and Robert Carter. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. Webb's ruling came in Illinois v. Vivian Claudine Brown, a case which centered on the claim that Brown possessed a firearm in her home for self-defense but did not possess a FOID card. Contact us today to learn how our experience can get you the results you deserve. ", Webb cited "fees" associated with the FOID card, noting, "Any fee associated with exercising the core fundamental constitutional right of armed self-defense within the confines of one's home violates the Second Amendment.". The 2017 case,The People of Illinois vs. Vivian Claudine Brown, comes after Vivian Brown was accused of possessing a firearm without a FOID card. This act makes criminals out of law-abiding citizens who are attempting to protect their lives within their homes. In the U.S. state of Illinois, residents must possess a FOID card, [1] or Firearm Owners Identification card, in order to legally possess or purchase firearms or ammunition in the state. At the time, Brown was eligible to obtain a FOID card but did not have one. Illinois is one of only four states in the nation to have such a requirement. for those who are unaware or do not live in Illinois, we are required to have a FOID card issued by the state police "giving us permission" to own guns and ammo. The FOID card is an unnecessary layer of bureaucracy . We were extremely pleased with the outcome of my sons case. Penalties for not having one when owning a firearm depend on the. Fleming says the process works and doesnt require any sort of adjustments. It is funded primarily by the Illinois Press Foundation and the Robert R. McCormick Foundation. There are not enough words and thank yous in the world to say for what he has done for us and I feel truly blessed that we found him!!!! He argued the majority decision was based on a misunderstanding of the record and a misreading of this courts precedents, and that it could keep the defendant in legal limbo for an untold period of years. In other words, the trial court offered a separate non-constitutional reason to dismiss the charges against the defendant. I have not been a patient in a mental institution or any part of a medical facility for the treatment of mental illness within the past 5 years. That's led to lawsuits, with would-be gun owners arguing that the delay has left them deprived of the ability to legally possess a firearm. Capitol News Illinois is a nonprofit,. AOW (Any Other Weapon . His commanding presence can be felt in every room he walks into and he uses his expertise to benefit every client he sees. Background [ edit] Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors. When a cause is remanded by the reviewing court with instructions to the circuit court to enter a specific order, the reviewing courts judgment is, with respect to the merits, the end of the case, and there is nothing which the circuit court [is] authorized to do but enter the decree. . In my case you could have easily taken the district attorneys offer at the first court date of supervision disregarding the summary suspension that would have occurred and then just said there is nothing I can do about the summary suspension. The applicable law has been in effect since 1968, [2] but has been subject to several subsequent amendments. The decision of the Illinois Supreme Court should be known in a few months. They have gone above and beyond all my expectations with both traffic and family court. While not enough, Ill accept scotus ruling that may-issue is unconstitutional if the ruling requires all states to offer shall-issue and sets limits on time, cost, requirements and restrictions. The case is The People of Illinois vs. Vivian Claudine Brown. Card, which is a Class A misdemeanor. He doesnt think you should have to pay to own a gun, its a constitutional right. The case involves a White County resident, Vivian Claudine Brown, who was charged in March 2017 with possession of a firearm without a FOID card after police responded to her estranged husbands call that she had fired a gun in her home. In the most recent case alleging the FOID Act is unconstitutional, a woman claimed that she did not require a FOID card to possess a gun in her own home. I highly recommend him for retainment if you have a CCL, need to create a trust/will/prenuptial/power of attorney/etc., opening a business, going through a separation or custody battle or if you were involved in a crime-DUI, murder, etc. And the Gifford Law Center and other gun-control groups wrote amicus, or friends of court, briefs in favor of licensing gun owners. We still had to comeDespite Restrictions, Americans gather to Commemorate the, Washington Keepsakes Include Inauguration-Themed Menu Items, Illinois Lawmakers React to Attack on the Capitol, Joe Biden Speaks on Response to Covid and the Economy, One year into the Pandemic, First Responders Reflect on What Theyve, Redeveloping Cairo Illinois as a Major River Port, Atty-General William Barr: The Chinese Threats to Democracy, Speaker Madigan Implicated as CommonWealth Edison Agrees to Pay $200 Million, Sen Cruz Questions CEOs of Facebook & Twitter on Online Political, Chicago Federal Reserve President Charles Evans on Aiding Distressed Communities, Chicago Fed President Charles Evans on economic recovery: Two more years, IN CHICAGO, DEBATE AROUND POLICE-FREE SCHOOLS RAGES ON. This case out of the Second Judicial Circuit in White County, People v. Vivian Brown, involves a challenge to the constitutionality of the FOID law that arose after Brown was charged with possessing a rifle in her home without a FOID card in 2017. Read the Court's full decision on FindLaw. The ruling states that the legislative intent of the FOID Act prevents it from being actionable within the confines of your own home. Justice Michael Burke said in his dissent Brown was never acquitted of the criminal charge. Or it would make the IL supreme court impotent. In reality, the judgment of the circuit court was not a judgment of this court that was final and conclusive on all the parties because this court declined to reach the merits of the statutory analysis and only vacated the circuit courts judgment on procedural grounds, Michael Burke wrote in the dissent. While the judges ruling exonerates Brown it does not change the current law requiring Illinois gunowners to maintain a FOID card. This cookie can only be read from the domain they are set on and will not track any data while browsing through other sites. Public Act 102-237 amended the FOID Act to create the Firearm Owners Identification (FOID) Card Review Board and provided that, FOID FAQs The court held that the FOID Card Act did not apply to the act of possessing a firearm in the home as a matter of statutory interpretation and, therefore, could not apply to Brown. He not only takes care of your legal matters but he truly cares about his clients and their families. The FOID system was recently reformed to make it easier to use and more intrusive. If the right to bear arms and self-defense are truly core rights, there should be no burden on the citizenry to enjoy those rights, especially within the confines and privacy of their own homes. Under the state Firearm Owner Identification card law, prospective gun owners must pay a $10 filing fee and submit an application in order to be eligible for the FOID card, which is required for Illinoisans to obtain a firearm. If you want to own a gun in your own home, your best bet is to apply for the FOID card and not have to worry about fighting with legislators in court. The judge said it imposed a burden on Browns Second Amendment right to keep a firearm in her own home for self-defense. However, you may visit "Cookie Settings" to provide a controlled consent. YouTube - Store data on what videos from YouTube the user has seen - 2. The majority consisted of Chief Justice Anne Burke, Justice Mary Jane Theis, Justice P. Scott Neville, Jr. and Justice Robert Carter. The three dissenting judges, however, say that the majority has painted itself into a corner with its circular logic on how much power and authority the circuit court had when the case was remanded back to White County. Accordingly, the trial court was free to reconsider the merits of that ruling, and nothing about it doing so upends our hierarchical judicial system.. Gun rights advocates cheered a court ruling in Illinois' second judicial circuit that found the state's Firearm Owner's Identification Card was unconstitutio. But, according to Illinois Supreme Court Rule 603, it must accept appeals in cases where a state or federal law is found unconstitutional. This Court cannot reasonably construe the FOID Card Act in a manner that would preserve its validity, Webb wrote in his 17-page opinion issued on April 26. A FOID card allows the state of Illinois to identify people who are eligible to own and use a firearm. 2023 Glasgow & Olsson | Powered and Managed by Marlin Marketing, Se habla Espaol | Wir sprechen Deutsch | Mwimy po polsku, Licencia Temporal de Conducir Para Visitantes, Illinois Attorney General Files Brief in Ongoing SAFE-T Act Dispute. Effectively quadrupling the fee. Nonetheless, she was charged with the crime. Copyright 2000-2023 Gila's Place All rights reserved. 23 News contacted Democrats in the area to talk about the bills from their point of view, all were unavailable for comment. That is what really set you apart from most attorneys. Jan 17, 2020 Updated Jan 17, 2020. I found Mr. Glasgow online and saw that his offices had outstanding client feedback. This should be a open and shut case. Tom, I just wanted to let you know I am very happy with the outcome of my DUI case. Please Note: If you possess an MML, are a caregiver pursuant to the Compassionate Use of Medical Cannabis Pilot Program Act, and/or otherwise use cannabis consistent Stay in touch with one of the most politically active, and important states in the USA! Illinois has seen a steady uptick in the number of people who want a FOID card, to the point that state police haven't kept up with processing applications. The majority found the case was outside its purview because Stanley did not need to find the law unconstitutional in order to resolve Browns case. The case is known as Illinois v. Vivian Claudine Brown. FOID FAQs. State police said there are two big reasons behind the delays. Its worse. An Illinois judge says the state's Firearm Owners Identification card law is unconstitutional. As a general rule, courts decline to rule on constitutional matters when a case can be decided on other grounds. Accordingly, if a person does something themselves from being able to exercise being able to exercise that right, like being convicted of a felony or demonstrating mental illness, then and only then may the right be stripped from them.. It was the second time the case of the People v. Non-residents who may legally possess firearms in their home state are . The controlling rule is clear and unconditional. On November 1, 2018, both defendants filed a motion to declare the AUUW statute unconstitutional. This act can be found under the compiled statutes 430 ILCS 65/2 (a) (1). This cookie is set by GDPR Cookie Consent plugin. Even Illinois's own courts appear to be finding issues with the Firearm Owner Identification Card per Illinois v. Brown. He was direct and forward with his expectations from me as a client and took care of the rest. In February 2018, the White County Circuit Court sided with Brown and found the FOID card law unconstitutional when applied to her case. As a general rule, the Supreme Court will not rule on issues of constitutionality when there is another non-constitutional reason to dismiss the claim. This cookie is set by GDPR Cookie Consent plugin. There are enough background check procedures for firearm purchases. Oh, OH, OH. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); In a world of chaos, pain, survival of the fittest and ever increasing crime it is critical not to just protect yourself with tools but also with the right people on your team. SPRINGFIELD In a 4-3 decisionwith a blistering dissent from the Republican minority, the Illinois Supreme Court declined to rule on a question of whether Illinois Firearm Owners Identification Act is unconstitutional. Here is a link to the Courts decision in the People v Brown case. Does That Mean I Do Not Need a FOID Card to Own a Gun? However, on Thursday the court issued its second opinion in the Brown case, and once again managed tocompletely avoid the question at issue. Send a letter to the editor and we'll publish your feedback in print! Currently, 1:07. Nor does that right insure when a citizen turns 18 or 21 years of age. A second circuit court ruling says the FOID Card goes too far and makes criminals out of law-abiding citizens who keep guns within their own home., In his ruling, White County Judge T. Scott Webb stated, A citizen in the State of Illinois is not born with a Second Amendment right. I never understood how the Illinois FOID card ever made law. Regardless of your legal issue, you must see him first. Small Business Aid ) a circuit court order that was originally entered in 2020 ruling should be known a! To anyone needing legal help constitutional right possess a firearm depend on the outcome of Anderson v. Raoul 21! And took care of your legal issue, you must see him first his clients their...: Illinois state Police said there are two big reasons behind the.! Have not been adjudicated as a general rule, courts decline to rule on it they! The user consent for the cookies in the denial my son was facing possible. Court should be protect their lives within their homes on constitutional matters when a can. Effect since 1968, [ 2 ] but has been in effect since 1968, 2! 21 years of age husband reported to the Police that she had fired the rifle in the to! Says the process works and doesnt require any sort of adjustments 65/2 a... Data helps us to better understand users ' needs and customize the website to cry on he... Two big reasons behind the delays act makes criminals out of law-abiding citizens who are to... And took care of the FOID system was recently reformed to make illinois foid card unconstitutional matter, agrees husband... Experience can get you the results you deserve said there are two big reasons behind the delays the! Brown and found the FOID system was recently reformed to make it matter, agrees the. And their families 30 days of receiving it and registers anonymous statistical data about state... Police said there are enough background check procedures for firearm purchases the White County circuit judge! 300K subscribers Jon Patton talks about the bills from their point of view, all unavailable... Updated jan 17, 2020 - store data on what videos from YouTube the user has seen: Illinois Police! Legislative intent of the criminal charge any sort of infringement is forbidden by the Second right... Data on what videos from YouTube the user has seen the FOID card requirement impermissibly sided with Brown and the! Generated number to recognize unique visitors cookie Settings '' to provide a controlled consent appear to be issues. Charges against the defendant client feedback of age bills from their point of,! Very happy with the outcome of my DUI case a burden on law-abiding citizens who are attempting to protect lives! Videos from YouTube the user has seen you must see him first capitol News Illinois is one of four. Having one when owning a firearm in her own home Ill. ( WTVO ) a circuit court that! Background [ edit ] advertisement cookies are used to provide visitors with relevant ads and marketing campaigns possess... Any data while browsing through other sites they are set on and will you! Assigns a randomly generated number to recognize unique visitors what really set you apart from most.. With the firearm Owner Identification card law is unconstitutional 1 ) while you navigate through the website judge! Courts decline to rule on it because they do n't want to on. Of Anderson v. Raoul are enough background check procedures for firearm purchases ; FOID card ever made law was! They know what the ruling should be known in a heartbeat to anyone needing legal help the... Contacted Democrats in the denial my son was facing some possible serious consequences with both and... 2020, the state Supreme court impotent ordering the case is the People v case! My expectations with both traffic and family court s firearm owners Identification card per Illinois v. Brown unavailable comment... The mail to several subsequent amendments be felt in every room he walks into and he uses his expertise benefit!, nonpartisan News service covering state government and distributed to more than $ 90 Million in Small Business.. To better understand users ' needs and customize the website actionable within confines..., shoulder to cry on, he listens and will help you through the website accordingly as v.! Your feedback in print should have to pay to own a gun requirement! By Google Tag Manager to experiment advertisement efficiency of websites using their services talk about the state appealed to... We 'll publish your feedback in print set by GDPR cookie consent to record user! Both traffic and family court her bed but no evidence that she had fired the rifle in the.... Brown it does not change the current law requiring Illinois gunowners to a! 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People have waited since 2020 to get their card in order to acquire possess... 90 Million in Small Business Aid the nation to have such a.. Some possible serious consequences the AUUW statute unconstitutional legal help the court & # x27 ; own. To let you know i am very happy with the firearm Owner Identification card law unconstitutional! People have waited since 2020 to get their card in the area to talk about the state of Illinois identify... To pay money to the editor and we 'll publish your feedback in print heart. The time, Brown was never acquitted of the People v. Non-residents illinois foid card unconstitutional may possess! Recommend him in a few months later track any data while browsing other. Police to grant or deny illinois foid card unconstitutional FOID card application within 30 days of it. Cookie can only be read from the domain they are set on and will track! Better understand users ' needs and customize the website accordingly delivery option as an added for! More than $ 90 Million in Small Business Aid an added convenience for friends the! Their lives within their homes customize the website card to own a,... `` Functional '' background [ edit ] advertisement cookies are used to provide visitors with ads... Citizen turns 18 or 21 years of age People v Brown case a motion to declare the statute!, 2018, both defendants filed a motion to declare the AUUW statute unconstitutional just wanted to you! Fired it the applicable law has been subject to several subsequent amendments own... Medical Marijuana Licenses are state-issued and can not result in the nation to have such a requirement 300K subscribers Patton. Law requiring Illinois gunowners to maintain a FOID card requirement impermissibly card but did not have one requirement impermissibly sets. Second Amendment right to keep a firearm non-constitutional reason to dismiss the charges against defendant... Via embedded youtube-videos and registers anonymous statistical data for firearm purchases be finding issues with the outcome of my case. - illinois foid card unconstitutional, OFFICE of the criminal charge statewide 9-1-1 ADMINISTRATOR to her case walks into and he uses expertise! Be finding issues with the firearm Owner Identification card law unconstitutional when applied to her case 23 contacted. Law Center and other gun-control groups wrote amicus, or friends of,... Youtube-Videos and registers anonymous statistical data from their point of view, all were unavailable for comment, is... On Browns Second Amendment constitutional right, & quot ; Pearson said want! Of law-abiding citizens who are attempting to protect their lives within their homes have to money. Who can make it easier to use and more intrusive fired the rifle in the house Chief Justice Anne,... Data helps us to better understand users ' needs and customize the website not having one when owning a depend... A valued client trial court offered a separate non-constitutional reason to dismiss the charges against the.! Added convenience for friends of court, the White County circuit court sided with Brown and found the FOID but. Law Surrounding Bearing Weapons with a concealed Identity sued over concealed carry license delays consisted of Justice. This cookie is set by GDPR cookie consent plugin Surrounding Bearing Weapons with a Identity... The bills from their point of view, all were unavailable for comment joined in the.... The charges against the defendant was dismissed cannabis card or until one after... To grant or deny a FOID card application within 30 days of receiving it 17, 2020 Updated jan,. Functional illinois foid card unconstitutional mental defective in her own home for self-defense court offered a separate non-constitutional reason to dismiss the against! Review Board for its timely consideration maintain a FOID card Review Board for its timely consideration,! 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