text: Post-ruling impacts Since the June 2008 ruling, over 80 different cases have been heard in lower federal courts on the constitutionality of a wide variety of gun control laws. These courts have heard lawsuits in regard to bans of firearm possession by felons, drug addicts, illegal immigrants, and individuals convicted of domestic violence misdemeanors. Also, cases have been heard on the constitutionality of laws prohibiting certain types of weapons, such as machine guns, sawed-off shotguns and/or specific types of weapons attachments. In addition, courts have heard challenges to laws barring guns in post offices and near schools and laws outlawing "straw" purchases, carrying of concealed weapons, types of ammunition and possession of unregistered firearms. There have been as of May 2019 more than 1,370 Second Amendment cases nationwide which challenged restrictive gun laws of various kinds since the Supreme Court issued its decision in Heller. In most cases the gun safety law or criminal conviction at issue has been however upheld by the lower courts. Provided with only minimum guidance from the Supreme Court in Heller the lower courts were tasked with defining the scope of the Second Amendment rights and the proper standard of review for evaluating Second Amendment claims in the aforementioned cases.
  The courts have upheld most of the above-mentioned laws as being constitutional. The basis for the lower court rulings is the dicta in the paragraph near the end of the Heller ruling that states:
  Consistently since the Heller ruling, the lower federal courts have ruled that almost all gun control measures as presently legislated are lawful and that according to UCLA professor of constitutional law Adam Winkler: "What gun rights advocates are discovering is that the vast majority of gun control laws fit within these categories."
  Robert Levy, the executive director of the Cato Institute who funded the Heller litigation has commented on this passage describing constitutionally acceptable forms of prohibitions of firearms: "I would have preferred that that not have been there," and that this paragraph in Scalia's opinion "created more confusion than light."
  Similar to the lifting of gun bans mentioned previously in the settlements of lawsuits filed post-Heller, in US v. Arzberger, also decided post-Heller, it was noted: