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 PART VII


Momentum for Prohibition

Gun control in Great Britain now proceeds on two fronts. When a sensational crime takes place, proposals for gun confiscations and for major new restrictions on the licensing system are introduced. During more tranquil times, fees are raised and increased controls are applied to relatively smaller issues.

An example of tranquil-period control was the Firearms Act of 1982, which introduced restrictive licensing for imitation firearms that could be converted to fire live ammunition. The original proposal had been to implement the 1973 Green Paper's outright ban on realistic imitation or toy firearms. The sponsor of the new law against imitation firearms promised that it would help stem "the rising tide of crime and terrorism," although he pointed to no crime or terrorist act committed with a converted imitation weapon. A new Crossbows Act outlawed purchase by persons under seventeen.[123]

Under new "safety" regulations regarding explosives, persons who possess modern gunpowder or blackpowder are now subject to unannounced, warrantless inspections of their home at any time to make sure that the powder is properly stored. The government, of course, promises that its inspections will not be unreasonable, but "reasonableness" is often in the eye of the beholder.[124]

While gun crime is not as common as in the United States, gun crime incidents inevitably attract sensational media attention that becomes the basis for further tightening of controls. In the fall of 1989, for example, a person who had been rejected for membership in a firearms club stole a handgun from the locked trunk of a club member and shot a Manchester policeman. In another case a probationary member of a firearms club, learning that he had a fatal disease, killed one club member, stole a gun from the club, and shot a personal enemy. The Home Secretary, at the urging of the Manchester police department, issued a new set of restrictions on firearms clubs, including sharp restrictions on bringing guests to a range to shoot a firearm.[125] The practical effect of the new restrictions was to reduce the entry of new members into many firearms clubs.[126]

Thanks to decades of such restrictions aimed at restricting entry into the shooting sports, the vast majority of the public has no familiarity with guns, other than what media choose to let them know.[127] Legal British gun owners now constitute only four percent of total households,[128] with perhaps another small percentage of the population possessing illegal, unregistered guns.[129] Given that many Britons have no personal acquaintance with anyone who they know to be a sporting shooter, it is not surprising that seventy-six percent of the population supports banning all guns.[130] Thus, the people who used long guns in the field sports--who confidently expected that whatever controls government imposed on the rabble in the cities who wanted handguns, genteel deer rifles and hand-made shotguns would be left alone--have been proven disastrously wrong.

Strong rights usually need a strong sociological foundation. Approximately half of American homes contain a gun, and a quarter contain a hand gun. Thus, except in a few cities like New York where gun ownership is rare, gun bans in the United States are nearly impossible to enact; too many voters would be unhappy. Consequently gun prohibition in the United States must focus on very small segments of the gun-owning population. That is why "assault weapon" bans, which cover only about one or two percent of the total firearms stock, are so much easier to enact than handgun bans. Even with "assault weapons," it is usually necessary to exempt the Ruger Mini-14 and Mini-30 rifles since these rifles, while functionally identical to banned guns, have too large an ownership base.[131]

A few sensational burglaries in the 1880s had created the first calls for restrictive British gun laws. A century later, some sensational crimes would initiate the final stages of British gun prohibition. In-between the 1880s and the 1980s, an initially reasonable and then gradually more restrictive licensing system had reduced the number of gun owners so far that they had little political clout. The gun-owners were of much less political significance than the media, which had become venomously anti-gun.

A. Hungerford

On the morning of August 19, 1987, a licensed gun owner named Michael Ryan dressed up like Sylvester Stallone's "Rambo" character and shot a woman thirteen times with a handgun.[132] After shooting at a filling station attendant, he drove to his home in the small market town of Hungerford, where he killed his mother and his dog. In the next hour, he went into town and slaughtered fourteen more people with his handgun and his Chinese-made Kalashnikov rifle. Ryan disappeared for a few hours, reappeared at 4 p.m. in a school, and killed himself three hours later.[133] A few days later, a double murder was perpetrated at Bristol, this one with a shotgun.[134]

The media's reaction, especially the print media's, was intense. The tabloid press ran editorials instructing the public how to spot potential mass murderers--advising suspicion of anyone who lived alone or was generally a "loner," who lived with his mother, or who was a bit quiet.[135] The tabloid press and the respectable press both pushed heavily for more stringent gun laws.[136] Pressure also mounted for tighter censorship of violent television.

The Hungerford atrocity was the only instance in which a self-loading rifle had been used in a British homicide. Punishing every owner of an object because one person misused the object might seem unfair, but two factors worked in favor of prohibition. First, the cabinet leadership observed that the number of owners of self-loading rifles was relatively small, so no important number of voters would be offended. Second, shotgun owners, who are by far the largest group of gun owners, generally decided that they did not care what the government did to someone else's rifles.[137]

Parliament responded. Semi-automatic centerfire rifles, which had been legally owned for nearly a century, were banned.[138] Pump-action rifles were banned as well, since it was argued that these guns could be substituted for semi-automatics. Practical Rifle Shooting, the fastest-growing sport in Britain, vanished temporarily, although participants eventually switched to bolt-action rifles.[139]

The shotgunners, however, made a disastrous error. The Association of Chiefs of Police had long been pushing to bring shotguns into the restrictive "Section 1" of the Firearms Act, which strictly controlled rifles and pistols. The ACPO worked out a deal with the Thatcher administration to take a major step in the ACPO's direction. As part of the legislation responding to a crime with a rifle, controls on shotguns were made significantly more stringent. There was little criminological rationale for the extra restrictions on shotguns; indeed, the extra police personnel required to administer the licenses would have to be diverted from other tasks. A Home Office Research Study written the year before Hungerford had concluded:

To make shotguns subject to the same controls as pistols ... would have considerable resource implications for the police .... Nor is there any real optimism that anything would be achieved by such a move since pistols ... are already subject to the very strict controls and yet ... are used in more cases of armed crime than shotguns.[140]

As a result of the 1988 law, shotguns that can hold more than two shells at once now require a Firearms Certificate, the same as rifles and handguns.[141] Moreover, all shotguns must now be registered. Shotgun sales between private parties must be reported to the police. Buyers of shot shells must produce a shotgun certificate. Applicants for a shotgun certificate must obtain a countersignature by a person who has known the applicant for two years and is "a member of Parliament, justice of the peace, minister of religion, doctor, lawyer, established civil servant, bank officer or person of similar standing."[142]

Most importantly, the law specified that an applicant for a Shotgun Certificate, which was required for shotguns capable of holding only one or two shells, could be denied if the applicant did not have a "good reason" for wanting to own shotgun. Although the statute placed the burden on proof on the police, to show that there was not a good reason, police practice immediately shifted the burden back to the applicant to show that she did have a good reason. Self-defense, of course, was deemed not to be good reason. Persons who were active members of shooting clubs, recreational hunters, and farmers engaged in pest control were all deemed by the police to have demonstrated good reason, but a person who merely wanted to retain legal possession of a family heirloom was not considered by the police to have a good reason.[143] By the time two cycles of renewals for the Shotgun Certificates, which were only valid for three years, had been completed, the number of legal owners of shotguns had fallen by a quarter. This sharply reversed the steady growth of gun ownership in the previous two decades.[144]

While the relatively liberal pre-1988 shotgun system had allowed significant growth in the number of legal shotgun owners, the greater police discretion over rifles and pistol licenses had allowed police to reduce continually the number of legal owners of rifles or pistols. The 256,000 holders of Firearms Certificates in 1968 had been cut to 173,000 by 1994.[145] Approximately one-third of the group of Firearms Certificate holders owned handguns.

The most important remaining difference between Firearms Certificates for rifles and pistols and Shotgun Certificates was that holders of the latter did not need police permission for every new acquisition. Once a person was granted as Shotgun Certificate, he could still acquire as many shotguns as he wanted, although he had to report each acquisition to the government. In contrast, Firearms Certificate holders have been required, ever since the original Firearms Act of 1920, to receive a police-granted "variance" for each new acquisition. Generally speaking, the police are skeptical about claims that Firearms Certificate holders have a "good reason" for wanting additional guns. Consequently, if a target shooter has one rifle in the .308 caliber, he will not be allowed to acquire a second rifle in the same caliber.[146] To bring all shotguns under Section one of the Firearms Act, a step which has not yet been taken, would have huge implications for shotgun acquisition. A person who legally owned one 12-gauge shotgun would not be allowed to own more than one.

Home Secretary Douglas Hurd told an audience that most the provisions in the 1988 Firearm Act had been prepared long before Hungerford, and the government had simply been waiting for the right moment to push them.[147]

B. Dunblane

The Hungerford cycle was repeated in 1996 when a pederast[148] named Thomas Hamilton used handguns to murder sixteen children and a teacher in Dunblane, Scotland. The man was well known as mentally unstable.[149] He had been refused membership in several gun clubs. Citizens had written to the police asking them to revoke the man's gun license. Under Great Britain's already restrictive gun laws, the police could easily have taken away this man's guns. Indeed, the police had already investigated him seven times, but had done nothing.

The tabloid press went wild with angry stories about gun-owners, portraying anyone who would own a gun as sexually inadequate and mentally ill. The Labour Party immediately called for a ban on all handguns over .22 calibre, using the same rationale that had been employed in earlier gun bans: "We can think of no good reason why a larger calibre handgun should ever lawfully be held for sporting purposes."[150] The fact that at least 40,000 Britons engaged in target shooting with guns over .22 caliber apparently did not qualify as a "good reason."[151] Thus, "good reason" continued its metamorphosis. In 1921, "good reason" had meant "the applicant has no nefarious purpose." In 1996, "good reason" meant "no reason can be good enough, if the gun is a handgun."

The Tory government, headed by John Major, convened a Dunblane Public Enquiry. The Enquiry received presentations on firearms policy from groups and experts on all sides of the gun issue. The most powerful submission, however, based on what the report concluded, came from the British Home Office. The Home Office presented a report citing claims from two international studies that high gun ownership rates--even legal, regulated gun ownership--caused high rates of criminal violence. These claims were seriously flawed; in Great Britain, within the United States, within Australia, and within continental Europe, the regions with the highest rates of legal gun ownership (such as rural England, the Rocky Mountain states, Queensland, and Switzerland) tend to have the lowest violence rates.[152] But the Dunblane Commission, misled by the Home Office, came back with a report that recommended dozens of ways to tighten the already-restrictive gun licensing system, and impose more controls on licensed gun owners.

The Home Office's deception of the Dunblane Enquiry highlights another condition that may increase slippery slope risks: the government's ability to produce "data" that "prove" the need for more government power. Deliberately misleading data from the government was hardly unique to the Dunblane Enquiry. In the United States, we have J. Edgar Hoover's production of false data about interstate car theft to boost FBI funding,[153] deceptive anti-gun research created by the federal Centers for Disease Control,[154] and a breathtaking variety of lies in support of the "War on Drugs"[155] to name just a few. Television, of course, can also be deceptive. In 1993, NBC News was caught red-handed rigging pickup trucks to explode and burn in order to support a news program.[156] Since the term "assault weapon" came into the media vocabulary, the technique of showing footage of machine guns firing in fully-automatic mode while the voice-over discusses other types of firearms has become routine. This practice continues even after the station acknowledges that the image is false or the result of outright fakery.[157]

While the Dunblane Enquiry did recommend many new controls, the Enquiry did not recommend banning all handguns.[158] Prime Minister John Major's Conservative government had decided to accept what it knew would be the Cullen recommendations, tightening the licensing system still more, but not banning handguns. However, then Labour Party leaders brought Dunblane spokesperson Anne Pearston to a rally, and, in effect, denounced opponents of a handgun ban as accomplices in the murder of school children. Prime Minister Major, who was already doing badly in the polls, crumbled. He promptly announced that the Conservative government would ban handguns above .22 caliber, and .22 caliber handguns would have to be stored at shooting clubs, not in homes.[159]

A few months later, Labour Party leader Tony Blair was swept into office in a landslide. One of his first acts was to complete the handgun ban by removing the exemption for .22s.[160] The Home Office was unable to produce any statistics regarding the use of .22 pistols in crime.[161] Prior data showed that the Firearms Certificate system worked about as well as any human system could to keep criminals from lawfully acquiring guns, or from stealing them from lawful owners. A study by the London Metropolitan Police Inspector of 657 armed robberies in the London area from January 1988 to June 1991 found that half the robberies were perpetrated with imitation firearms. Of the remaining 328 real weapons, only one involved a gun which had ever been within the Firearms Certificate system.[162] Dunblane was the only British mass murder in this century with a lawfully registered pistol. But gun ownership in general, and pistols in particular, had become rare, and consequently anathematized, once a few generations had grown up under the regime created by the Firearms Act of 1920. A two-to-one majority in Parliament found it commonsense that the crime of one person should lead to the collective punishment of 57,000 others.

Since 1921, all lawfully-owned handguns in Great Britain are registered with the government, so handgun owners have little choice but to surrender their guns in exchange for payment according to government schedule. Gun registration has laid a foundation for confiscation not only in Great Britain, but also in New York City, where the 1967 registration system for long guns was used in the early 1990s to confiscate lawfully owned semiautomatic rifles. Nevertheless, United States gun control advocates continue to insist that the United States gun rights advocates are "paranoid" for resisting registration because it might lead to confiscation. The gun control advocates reason that they do not intend to confiscate registered guns. However, the gun control advocates fail to consider what their successors might advocate. The British Parliament who created the gun registration system in 1920 had no intention of banning handguns. But that 1920 Parliament failed to foresee the danger that a registration system, even if created with the best intentions, could later be used for confiscation. Thus, it is eminently sensible for civil liberties advocates in the United States to resist registration of persons who exercise constitutional rights, not because registration is excessively burdensome in itself, but because registration amounts to greasing the slippery slope.[163]

C. The Next Steps

The handgun ban by no means has satiated the anti-gun appetite in Great Britain. When Scottish handgun owners dutifully surrendered their handguns many of them applied for permits to own rifles or antique handguns that remained legal. The Scottish Home Affairs Minister announced that he wanted "to send a very powerful message" against acquisition of alternative "weapons [that] are currently legal." He announced that the Scottish government would begin considering whether to tighten controls on shotguns.[164] Consequently, while British gun owners gracefully gave away the right to own guns for protection, they are now finding their privilege to own guns for sport is under greater attack than ever. Britain's leading anti-hunting group, the League Against Cruel Sports, points to the "hundreds" of people killed by guns and "thousands" of guns used in robberies and demands a ban on all guns.[165] The Blair government has announced plans to study whether airguns[166] should be brought into the gun licensing system, and whether the age limit on gun possession should be raised, which would prevent most teenagers from using firearms, even under adult supervision. A ban on all rifles above .22 caliber except for deer hunting is expected, along with a requirement that shotgun owners receive government permission each time they acquire a shotgun, as rifle owners currently must.[167]

A ban on all real guns will probably not suffice, however. Many British gun owners now own deactivated "replica" guns that cannot be fired. The guns are merely decorative pieces, and are less dangerous than a cricket bat. For some gun owners, deactivation was the only way they could retain possession of a prized semiautomatic. Other gun owners simply found the hassles of the police licensing system too much to overcome, and had their family heirloom guns deactivated into non-firing ex-weapons. With deactivation, at least, the family could retain the gun without need to spend vast sums on police security requirements. This last "loophole," however, in the British gun laws may be closed in a few years, as the police are now lobbying to require that owners of deactivated or replica guns get the same license that would be required for guns which can fire ammunition.

Have all these controls and abusive enforcement of controls actually made Britain safer? Armed crime in Britain is higher than it has been in at least two centuries. Armed crime is literally one hundred times more common than at the turn of the century when Britain had no weapons controls. Crime victimization surveys show that, per capita, assault in England and Wales occurs between two and three times more often than in the United States. These same surveys demonstrate that robbery occurs 1.4 times more, and burglary occurs 1.7 times more.[168] In contrast to criminologists in the United States, British criminologists have displayed little interest in studying whether their nation's gun laws do any good. Accordingly, definitive statements about cause and effect should be avoided. One can, however, say that as British gun laws have grown more severe, the country has grown more dangerous.

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[123] Some Britons favor putting all bows under a licensing system identical to that for guns. The crossbow, which has historically associated with highwaymen, will likely be controlled first, since long bows, which have been associated with English military valor at Agincourt and other medieval battles, have a better pedigree.

[124] In the United States, Handgun Control, Inc., has proposed "Brady II" legislation that would make many American gun-owning homes subject to four unannounced warrantless inspections per year.

[125] See Home Office, Gun Clubs: Home Secretary Plans New Controls (press release), November 14, 1989.

[126] Persons who hold a Firearms Certificate do not need government permission in order to form a private club and shoot together at a target range they build, but government approval is necessary if club members wish to be able to shoot each others' rifles at the range, or occasionally to invite guests who do not have a Firearms Certificate. Cadmus, Abuse of Authority, 36 Guns Rev. 25, 25 (1996).

[127] See generally, e.g. Pat Kane, We Have to Be Careful Out There, Sun. Times, May 22, 1994 ("a fascination with guns around the darker fringes of the male psyche ... men of this generation are so fundamentally insecure about their personal power that guns could seem a ready option"); Lynne Truss, The Times, May 24, 1994 ("It's the chaps who fire relentlessly at targets that it's hard to understand, who seem most creepy and dangerous."); Dressed to Kill--Just for Thrills, The Observer, Sept. 12, 1994.

[128] See Martin Killias, Gun Ownership and Violent Crime: The Swiss Experience, 1 Sec. J. 171 (1990).

[129] See Kopel, supra note 2, at 89-90 (using gun seizure, gun surrender, and gun registration data to estimate size of illegal gun supply and gun ownership in Great Britain).

[130] See Gallup Poll from 1988, discussed in R.A.I. Munday, On Liberty (unpublished essay).

[131] See Memorandum from S.C. Helsley, Assistant Director, Investigation and Enforcement Branch, California Department of Justice, to G.W. Clemons, Director, Division of Law Enforcement, California Department of Justice 1 (Feb. 13, 1991) (on file with authors). See generally Bruce H. Kobayashi & Joseph E. Olson, In Re 101 California Street: A Legal and Economic Analysis of Strict Liability for the Manufacture and Sale of "Assault Weapons," 8 Stan. L. & Pol'y Rev. 41 (1997).

[132] It was not surprising that a murderous psychopath would choose to dress up like "Rambo," the machine-gun spraying character popularized by Sylvester Stallone. Ironically, Stallone, who now lives in Great Britain, touts gun prohibition and criticizes gun policies in the United States for being uncivilized. Perhaps before demanding a government crack down on law-abiding American gun owners, Mr. Stallone ought to apologize for his own role in spurring mass murders by the mentally deranged, including at Hungerford.

[133] See Malcolm P.I. Weller, The Anatomy of Violence--Part I, New L.J. Sept. 11, 1987, at 858.

[134] See Tony Jackson, Legitimate Pursuit 48 (1988).

[135] See Woody Haut, Hysteria, the Free Market, and the Hungerford Massacre, Rolling Stock No. 14 (1987), at 15.

[136] See Jackson, supra note 134, at 92, 99 (quoting Daily Telegraph, Daily Mirror, Daily Express, Yorkshire Evening Press).

[137] See Cadmus, Section Five, 33 Guns Rev. 42 (1993).

[138] Opponents of the ban had argued for a special exemption for disabled people, since semiautomatics have low recoil, and are hence easier to shoot for persons with less upper body strength. One pro-control Lord replied that a handicapped person "would probably have a harder job to hold on to the rifle than an able bodied person if someone wanted to steal it." Lord Atlee worried about the possibility of "a disabled person who was also mentally unstable." House of Lords, Official Report, Oct. 19, 1988, at cols. 1134, 1131.

[139] See Capt. Bruce Breckenridge, A Shooting Sport is Dead, Australian Gunsports, Summer 1990, at 60.

[140] Home Office Research Study No. 89 of 1986, quoted in Jersey Pistol Club News, Jan.-Mar. 1991, at 5.

[141] See Firearms (Amendment) Act, 1988, ch. 16, 2(1)(2) (Eng.).

[142] See Sandys-Winch, supra note 98, at 29 (citation omitted). See also George Wallace, Counter signatory Rears Ugly Head, Shooting Times & Country Magazine, Oct. 12-18, 1989, at 8. A somewhat weaker countersignature requirement had already been in force for shotguns. See Fiddick, supra note 67, at 10. That requirement had been imposed by the police without statutory authority. A 1984 Police/Home Office working group had found the countersignature useless, and advised abolition. See Cadmus, Conspiracy to Disarm, 31 Guns Rev. 926 (1991).

[143] See Cadmus, Good Reason Abuse, 29 Guns Review 862 (1989).

A police decision regarding good reason will not be overturned by the courts unless it is arbitrary and capricious. See Hutcgusib v. Chief Constable of Grampian, 1977 S.L.T. 98 (Sheriff Ct.).

Home Office guidance states that the good reason language for shotguns "does NOT require the applicant to make out a good case for being granted a certificate but rather extends the chief officer's ground for refusing one." Firearms Law--Guidance to Police, 7.6, quoted in Lorton, supra note 43, at 72.

[144] In 1969, there were 701,562 Shotgun Certificates. By 1988, the number had risen to 971,102. By 1994, the number had declined to 740,441.See Cadmus, The Villains, 35 Guns Rev. 925 (1995) (citing data from the Home Office).

[145] See id.

[146] See Cadmus, The Dangerously Ugly, 33 Guns Rev. 926 (1993).

[147] See Richard Law, Shooters Rights, Guns & Shooting, Sept. 1993, at 54 (discussing Hurd's speech to students at St. Edwards, Oxford).

[148] SeeCullen, supra note 99, at ch. 5-6.

[149] See Saray Lyall, Scottish School Killer Had Stormy Past, N.Y. Times, Mar. 15, 1996, at A6.

[150] George Robertson & Jack Straw, Control of Guns: The Labour Party's Evidence to the Cullen Inquiry (May 1996), available at <http://www.cybersurf.co.uk/~johnny/dunblane/labour.html>.

[151] See Office of Legislative Affairs, Lord Cullen's Inquiry into the Circumstances Leading up to and Surrounding Events at Dunblane Primary School on Wednesday, 13 March 1996, at 11.

[152] See R.A.I. Munday, Does the Level of Firearms Ownership Affect Levels of Violence? (Submitted to the Dunblane Enquiry 1996); Peter H. Jackson et al., Was the Dunblane Inquiry Misled? (Nov. 9, 1996), available at <http://www.cybersurf.co.uk/~johnny/dunblane/misled.html>.

[153] See David Barnham, Above the Law 86-87 (1996).

[154] See, e.g., Don B. Kates et al, Guns and Public Health: Epidemic of Violence or Pandemic of Propaganda? 62 Tenn. L. Rev. 513 (1995).

[155] See, e.g., Lynn Simner & John P. Morgan, Marijuana Myths, Marijuana Facts: A Review of the Scientific Evidence (1997).

[156] See Brian Dylan, After the Blowup, U.S.A. Today, Feb. 11, 1993, at 1.

[157] See Scott Baltic, Bang Bang! You're Wrong!, Colum. Journalism Rev., Feb. 1994, at 11 (criticizing the media for gross inaccuracy in the assault weapon debate). See also Wound Ballistics Expert Exposes Media AK Fakery, Gun Week, May 5, 1989, at 1 (describing phony footage of AK-47 assault rifles staged for television news program); Joseph Tartaro, The Great Assault Weapons Hoax, 20 U. Dayton L. Rev. 619 (1995).

[158] See The Hon. Lord Cullen, The Public Inquiry into the Shootings at Dunblane Primary School, Mar. 1996, at 13 <http://www.official-documents.co.uk/document/scottish/dunblane/dunblane.htm>.

[159] See Norman Cooper, Time to Remove the Gloves, 37 Guns Rev. 56 (1997) (Sir Patrick Lawrence, former Chair of the Conservative Party, told Cooper that the Anne Pearston rally caused Major's switch). The ban was implemented by the Firearms (Amendment) Act 1997, 1997, ch. 5 (Eng.).

[160] See Firearms (Amendment) (no. 2) Act, 1997, ch. 64 (Eng.). Labour's original proposal to the Cullen Inquiry was that single-shot .22s, which need to be reloaded after each shot, should remain legal, but the Party's aggressive use of focus groups and polling had apparently convinced Blair to go further.

[161] See Dominic Grieve, Hansard, June 11, 1997, at pt. 43, col. 1232.

[162] See Hawkins, Hansard, June 11, 1997, at pt. 39, col. 1212.

[163] But see Lamont v. Postmaster General, 381 U.S. 301 (1965) (holding that postal regulations requiring those who receive "foreign Communist propaganda" by mail to complete a short registration form is an excessive burden on the exercise of First Amendment rights).

[164] James Rougrie, Shotguns Review on Cards, Says McLeish, The Scotsman, Nov. 4, 1997, at 6, quoted at <http://www.cybersurf.co.uk/~johnny/dunblane/scot4nov.html>.

[165]Tony Jackson, Legitimate Pursuit: The Case for the Sporting Gun 94 (1988).

[166] Airguns are powered by compressed air, rather than by gunpowder and they fire a small pellet or a BB.

[167] See Jason Bennetto, Purge on Rifles and Shotguns, The Independent, July 17, 1997, at 1.

[168] See Patrick A. Langan & David P. Farrington, Crime and Justice in the United States and in England and Wales, 1981-96 (1998)