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the state, but, once again, challenge the extent of influence these exceptions hold. Part IV analyzes the information provided in an attempt to answer the questions presented. Michigan’s case law suggests that universities have the authority to limit the carrying of firearms on their campuses; other public policy priorities, however, likely limit that ability. Part V summarizes these suggestions in a succinct conclusion and attempts to glimpse at the immediate future of the issue. II. A.
BACKGROUND
AMERICA’S CONSTITUTION AND THE RIGHT TO CARRY
Since its inception, the right to possess and carry a firearm has been engrained in the framework of America’s Constitution.2 Subsequently, “the framers and ratifiers of the Fourteenth Amendment counted the right to keep and bear arms among those fundamental rights necessary
2. U.S. CONST. amend. II (“A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.”). Although simple in language, the Second Amendment has been subject to disparately contradictory interpretations. Especially relevant to this article is the term “to . . . bear Arms.” The Supreme Court recently defined the term’s natural meaning as “[t]o wear, bear, or carry . . . upon the person or in the clothing or in a pocket, for the purpose . . . of being armed and ready for offensive or defensive action in a case of conflict with another person.” District of Columbia v. Heller, 554 U.S. 570, 584 (2008) (citing Muscarello v. United States, 524 U.S. 125, 143 (1998) (Ginsberg, R.B., dissenting)). The Heller Court used that definition as part of its interpretation that “[to] bear arms” was unambiguously used to refer to the carrying of weapons outside of an organized militia as a broader provision which recognized “the natural right of defense of one’s person or house.” Id. (internal quotation omitted).