"The Sullivan Law was passed, in good part, as an effort to disarm Italian immigrants, whom many believed were predominately responsible for violent crime in New York City in the early 20th century."
"This history is important not because the conditions that existed over a century ago are still present, but because it illustrates the ineluctable danger when the exercise of a fundamental right rests upon the discretion of a few."
"Nonetheless, the narrative that Italians were predisposed to violent crime only grew despite studies showing that the vast majority of Italian immigrants were law-abiding and no more prone to crime than the native-born."
"That meager harvest was enough to make headlines, though, for as one New York City officer had noted a few years earlier, '[w]hen an Italian does anything it is printed in big type.'"
"The article then spread the alarm further, declaring that Italians were committing a daily average of at least two shootings or stabbings in the New York area that year."
"Francis Corrao, an Assistant District Attorney in the City, had vowed to take on the Black Hand, convinced that many Italian immigrants were leaving Brooklyn because the law was indifferent to protecting them from violence."
"While some newspapers denied the presence of any formal criminal organization, other newspapers warned of the 'ignorant, dirty, low-browned aliens' who terrified the City as a group."
"Pennsylvania also mobilized against what it deemed threats to wildlife created by Italian immigrants who, in the eyes of some, brought their lax hunting discipline with them from Italy."
"The New York Times endorsed further gun laws that 'would prove corrective and salutary in a city filled with immigrants and evil communications, floating from the shores of Italy and Austria-Hungary.'"
"The raids were so thorough that the City Magistrates and police 'believed that the habit now so prevalent among the Italians of New York of carrying revolvers, dirks, knives, and stilettos will soon be wiped out.'"
"Officers in New York City were ordered to arrest as many Sicilian suspects in the City as possible."
"According to one newspaper, '[t]he raids were said to be a part of the plan to discourage the meeting of large numbers of Italians.'"
"The turning point came late in 1911 when State Senator Big Tim Sullivan, known as 'the political ruler of down-town New York' made the decision to support firearms restrictions."
"In the first part of his speech, Sullivan touted a law he had passed the previous legislative session regulating small, private banks, many of which were 'operated by men who were foreign born,' and singling out those from Italy."
"Some gangsters who had fallen out of favor with Tammany sewed their pockets closed so guns could not be planted on them."
"Two years earlier, Sullivan had proposed disarming police in the City of their nightsticks, an idea that the Times implied was an effort to make police less able to defend themselves against the criminals Sullivan himself employed."
"Most prominent was John D. Rockefeller, whom Sullivan introduced to the Senate as a 'social acquaintance' and who in 1908 was cheered for dismissing all the Italians working at his Westchester County estate and hiring non-Italian locals."
"The New York Times applauded the sentence and admonition to the 'hot-headed' Italians, noting that '[t]he Judge’s warning to the Italian community was timely and exemplary.'"
"Kessler explained that he, like Rossi, carried a revolver 'for protection against gangsters' because he worked late in a dangerous part of the City, but 'did not get a permit because he did not feel that he could spare $10 of his small wages to carry a $5 revolver.'"
"Another key provision of the new Sullivan Law made it a felony for any alien to have a firearm or other dangerous or deadly weapon in public."
"Carr urged the newcomers: 'Italians are too ready to have recourse to violence in quarrels. If this habit could be given up, Italian immigrants would at once find themselves more welcome in America; for this is the one thing that that makes them distrusted.'"
"Police determined that the explosions were caused by fireworks thrown by gang members trying to create sufficient reason to be granted permits."
"We ask that the Court find New York’s discretionary permitting law in violation of the Second Amendment so that all law-abiding Americans, whatever their last names and circumstances, may exercise this fundamental right."
"Counsel of Record is an Assistant General Counsel at the National Rifle Association (the 'NRA') and wrote this brief in full."

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