Yesterday, a three-judge panel of the United States Court of Appeals for the Seventh Circuit voted 2-1 to overturn an injunction against Illinois’ “assault weapons” ban. The panel declared that AR-15s are not protected by the Second Amendment in overturning the preliminary injunction win in Barnett v. Raoul by U.S. District Judge Stephen P. McGlynn. The case could set up a major test for gun rights for the United States Supreme Court.
Notably, the majority was composed of conservative judge Frank Easterbook and liberal judge Diane P. Wood. Conservative judge Michael P. Brennan dissented.
The majority stressed that in Heller the Supreme Court held, “[l]ike most rights, the right secured by the Second Amendment is not unlimited.” They further noted that the court has previously found that machine guns are not protected under the Second Amendment because they were not “bearable” arms under the Second Amendment.
While gun rights advocates have stressed the similarities with other clearly protected weapons, Easterbrook and Wood stressed the similarities between AR-15s and M16s:
The similarity between the AR-15 and the M16 only increases when we take into account how easy it is to modify the AR-15 by adding a “bump stock” (as the shooter in the 2017 Las Vegas event had done) or auto-sear to it, thereby making it, in essence, a fully automatic weapon. In a decision addressing a ban on bump stocks enacted by the Maryland legislature, another federal court found that bump-stock devices enable “rates of fire between 400 to 800 rounds per minute.”
In an analysis that will likely be challenged by gun rights advocates, they stressed that the guns use the same ammunition and “deliver the same kinetic energy.” The kinetic energy used in AR-15s are also analogous to clearly protected weapons.
President Biden has repeatedly made another argument on velocity that has been challenged in these comparisons. A June 30 Field & Stream column on the “Five Fastest Rifle Cartridges” listed the feet per second (fps) the five fastest rifle cartridges:
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.220 Swift — A 40-Grain .220 Swift round moves approximately 4,300 fps.
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.257 Weatherby Magnum — An 87-Grain .257 Weatherby Magnum round moves approximately 3,700+ fps.
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.30/378 Weatherby — An 165-Grain .30/378 Weatherby round moves approximately 3,400+ fps.
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.224 Clark — An 80-Grain .224 Clark round moves approximately 3,500+ fps.
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.22 Eargesplitten Loudenboomer — A 50-Grain .22 Eargesplitten Loudenboomer round moves approximately 4,600 fps.
AR-15 rounds move at approximately 2,700 – 3,100 fps. Even handgun bullets can reportedly reach around 2,000 fps (though that is rare).
Even the Washington Post has called Biden’s repeated velocity claim “bungled” and factually incorrect. An AR-15 round, at 100 yards, is only slightly faster than most hunting rifles. However, when measured at the point of the departure from the barrel (as is commonly used on velocity), it is about twice the speed of a common hand gun. It is not the fastest (let alone five times faster) than other guns.
Judge Brennan’s dissent focused not on Heller but Bruen from 2022. He stressed the historical analysis used by the court and wrote that “because the banned firearms and magazines warrant constitutional protection, and the government parties have failed to meet their burden to show that their bans are part of the history and tradition of firearms regulation, preliminary injunctions are justified against enforcement of the challenged laws.”
Notably, the Supreme Court just took two new cases touching on the Second Amendment. National Rifle Association of America v. Vullo concerns free speech over companies doing business with a controversial speaker. The case involves the blacklisting of the National Rifle Association in New York.
The second case, Garland v. Cargill, considers whether a bump stock device is a “machine gun” as defined in federal law.
Here is the AR-15 decision: Seventh Circuit Opinion
For about 15 years, your state’s “Fusion Center” likely has the capability to prevent most mass shootings from military grade assault weapons. These Fusion Centers have the capability today to monitor all owners of military grade assault weapons.
Without spending an addition dime to taxpayers, Fusion Centers could track those weapons simply by switching priorities.
For the past 15+ years, Fusion Centers have been tracking non-criminals, non-terrorists and non-violent Americans – most more law abiding than many gun owners.
These FCs have been violating constitutional rights for almost two decades and violating U.S. Supreme Court rulings like “Carpenter v. US” and “US v. Jones”.
Congress and your state legislature have granted FCs almost unconditional secrecy and exempted them from most FOIA requests – even for non-terrorism cases – cases governed by the Bill of Rights. The Freedom of Information was literally gutted without debate amongst the voters.
It’s curious that constitutional conservatives and gun owners, have been silent for almost 20 years about this constitutional crisis!
Fusion Centers can very effectively track any gun owner in any school district or other targets of mass shooters – without increasing taxes one dime.
So in the Judicial majority opinion, the volicity of a bullet makes it more lethal not the location the round strikes someone? A bizarre and wrong opinion!
@MRR
If it were the lethality of the round then bolt action rifles which fire more powerful cartridges would be banned.
Midway in your article you refer to President Bush. I believe you may have meant Biden.
Potato v. mashed potato, still potatoes though.
A more useful comparison might be to the commercial .222 Remington cartridge introduced in 1950 that the .223 was derived from. Velocity of the .222 is 3100-3500 fps. That is comparable to the velocity of a .223 round from an AR-15.
Including Biden’s idiotic claim of velocity would have made the post clearer. It was “Do you realize the bullet out of an AR-15 travels five times as rapidly as a bullet shot out of any other gun, five times”
That would make the round seriously hypersonic at around mach 15. If true that would be quite an accomplishment. There is no truth to Joe’s story that the sonic boom from an AR-15 round killed his son.
Kinetic Energy is just one physical property when it comes to ballistic analysis. It would be like…
Kinetic energy is just a number that indicates the ability of a moving bullet to do work. The way a bullet performs is more important and is defined by its design and velocity as opposed to just its kinetic energy. Comparing loads or cartridges based solely on kinetic energy makes as much sense as picking a wife based on bust size. Big numbers are impressive, but can be misleading when it comes to performance.
https://www.shootingillustrated.com/content/kinetic-energy/
😉
No better summary of the legitimacy of the AR-15 under the protections of the 2nd Amendment than the one The Honorable Judge Roger T. Benitez issued on October 16, 2023. https://www.courthousenews.com/wp-content/uploads/2023/10/miller-v-bonta-order.pdf?utm_source=emailoctopus&utm_medium=email&utm_campaign=Defending%20Gun%20Rights%20Against%20California
“[T]he constitution states nothing about ammunition.”
That is a perfect example of a fascist view of rights. Individuals *possess* rights, but only in name or title. Government controls how you *use* and act on that right — e.g., speech, property, guns.
One you sunder possession from use, your rights are gone.
This Decision completely ignores Miller v. US which said that the 2nd specifically applied to weapons that are in common use by the military, due to the Militia clause. A strict reading on that would say your hunting 12 gauge isn’t necessarily protected, but your AR definitely is.
“assault weapons”
The pejorative “assault” is a Leftist emotional manipulation — designed to frighten people into surrendering a rights.
“Assault” means “a physical attack.”
Is there a single gun, knife, or fork that cannot be used for a physical attack?
@Sam,
The reason they use ‘assault weapons’ because the ‘Assault Rifle’ has a specific definition and is a true weapon of war.
The term assault weapon is a legal fiction which is defined by the specific document as to its meaning.
“a specific definition”
Such as?
“defined by the specific document”
What “document?”
The Courts have demonstrated two things….Liberals shall push an agenda via the Court System and that they know nothing of guns.
The horrid black rifle…the AR-15 that uses a .223 caliber projectile and a 30 Round Magazine that can be modified to fire in an “automatic mode”…..that now comes in all sorts of colors and descriptions.
Yes it can be modified by means of a bump stock but then the exact same effect can be achieved by a simple but clever use of a human thumb.
Yes it can modified by use of an auto sear mechanism which in and of itself is illegal to possess already and that it takes a machinist to mill the Receiver to accept the Auto Sear Trigger Assembly.
Yes it holds a 39 Round Magazine but so do other rifles besides the horrid black AR-15.
Now as the perfect example of the Left’s ignorance of firearms.
Do you ever hear them rant about the Mini-14 Rifle that is made by the Ruger Company?
No….you do not….becauxe it has a wooden stock, holds a 30 round magazine, fires the exact same cartridge as that horrid black AR-15 and can be modified to fire in automatic mode.
Then there is the .30 Caliber Carbine that can be fitted with a black stock, holds a 30 Round magazine and if you run across an M-2 trigger assembly or M-2 Receiver it is an automatic firing rifle that uses a .30 caliber bullet that is much larger than the .223 cartridge.
Federal law makes any component, part, assembly, receiver, or trigger that makes a firearm operate in “automatic” mneaning one pull of the trigger can allow the firearm to discharge a projectile until the trigger is released…..in the case of horrid black rifle, the Mini-14, and the M-1 Carbine that could be 30 bullets with one pull of the trigger if they have been illegally modified or possessed. The Law already exists that makes mere possession a Felony Crime much less the use.
The Left also has a conniption fit over a pistol hand grip and insists that adding such makes the weapon an “Assault Weapon”.
Folks, that is pure bunk…..pure BS….and just plain the thinking of a dumbass!
Take any ol’ trusty Remington 870 shotgun….used for all sorts of hunting, target shooting, and stop sign killing by millions of folks….well maybe not in the killing of stop signs.
The Left would have you believe by replacing the wooden stock and putting on a black stock with a pistol grip that instantly converts the shotgun (the mechanical part that discharges the shot shell) into an assault weapon.
Now the example…..for home defense now….but originally bought to be a combination survival weapon required by Alaska Law for aircraft…..and Brown Bear Defense weapon…..my trusty 870 was modified by extending the magazine to increase the number of shells it would hold…..remember how big and aggressive Brown Bears can be….and it now holds several more shells than the typical 870 but is legal, never gets any mention by the rabid Left but is far more capable than the standard 870.
But….But….if I add a black stock. or folding stock (the gun came with a folding stock for making it more compact to store inside the aircraft) it by the Left’s thinking becomes an evil assault weapon. When it is for defense only.
The Left cannot and shall not ever admit it is not the gun but rather it is the Human finger on the trigger the tis root cause of the problem and by that refusal and rejection to do so shall never come up with a solution to the problem which is Human Beings with mental problems having access to fire arms.
In almost every case of mass murder in this country the killer is known to the authorities, family, friends, and social media followers…..yet the Killers are able to gain or retain access to firearms.
Those that knew of the potential of violence by an individual did nothing or even if they did….the SYSTEM FAILED to protect us.
The other thing that the Left shall never admit, accept, tolerate or concede is that Good Men with guns do save lives and as has been demonstrated by reality……end mass killings when Good Men with guns are present to do so.
The system has failed society.
More wrong headed laws shall do nothing but disarm the victims as those intent upon murder shall find a way.
Tim McVeigh used fertilizer and a Rental Truck, the guy in Wisconsin used a SUV, folks in Chicago use handguns, and the Left does it by going after the symptoms rather than dealing with the reality and root causes.
The Court decided wrongly in this case.
If the ATF,DOJ, and State Authorities enforced the current laws….AND the Courts levy effective penalties for those violations….AND we do something about the American Mental Health system…..that is right and proper way of ending this scourge that is upon us. Does anyone think that those who ignore the current law shall obey any new law when they are pre-disposed to commit murder? Just look at Chicago folks…..there is your proof.
@Ralph…
Lets get some simple facts out in the open…
1) Its already illegal to convert a semi-automatic weapon into a full automatic or select fire weapon.
2) The bump stock doesn’t make a semi-auto weapon into a full auto weapon. The trigger pull is still one round per trigger pull therefore the firearm is still semi-auto.
3) Things like the glock switch which does make the glock pistol into a full auto pistol is already illegal because the switch is considered a machine gun.
4) the level of effort to turn a semi-auto rifle into a full auto is not simple and would require some time in a machine shop by a skilled machinist.
The other thing… there are individuals who have taken the time to be able to shoot pistols and revolvers at high rate of speed with insane accuracy.
So if you look at rate of fire… you don’t need a machine gun to be deadly.
Not disagreeing with what you said… just wanted to make it a bit more succinct.
-G
“. . . not protected under the Second Amendment because they were not “bearable” arms under the Second Amendment.”
When you wish to usurp a right, cherry-pick its words.
The actual wording is:
“. . . to *keep* and bear Arms . . .” (Emphasis added)
“Keep,” as in possess (not just carry).
Each amendment of the Constitution will be attacked when it doesn’t agree with the those who fundamentally wish to change the United States of America.
Did you see one American flag mixed in with the foreign flag held by protesters the past few days?
ATTENTION!!!!! Transcript from the signing of the US Constitution discovered!!
Transcript notes have been cross referenced with the painting ‘Scene at the Signing of the Constitution of the United States’. And the notes confirm the details regarding the wording of what Alexander Hamilton is whispering into Ben Franklin’s ear: “Ben, are you sure that the Second Amendment takes into account muzzle velocity and round speed at 100 yards?”
I well regulated militia at the time of the Founding meant a local militia Captain exercised loose supervision over firearms use. He was responsible for disarming:
– immature boys
– drunks
– wife beaters
– criminals
– loyalists
– the insane
– the paranoid
– old age demented
You didn’t have mass shootings like we are experiencing now, because the militia firearms were supervised.
Public safety was balanced with self-defense. That gives weight to the prelude “a well regulated militia”.
Nobody needs an AR-15 for self-defense, just like they don’t need machine guns or RPGs. Beyond that, we should have a modern, decentralized system of loose supervision. One would be to require an older “sponsor” to vouch for young firearms owners — co-signing at the point of purchase, and accepting criminal and civil liability for any illegal or unintended use of the weapon. That way, responsibility is widely dispersed, and cannot be concentrated by authoritarian government. We can solve the mess that under-regulation and gun zealotry has created. It’s just common sense that gun ownership is overseen by responsible, mature, stable members of society. That will prevent deranged individuals from going on rampages. We don’t need judges making these decisions — just ordinary folks.
Your list of things “nobody needs” is woefully incomplete, and inaccurate. Your qualification that an AR-15 must be limited to ‘self-defense’ is wishful thinking.
Your (and the lemmings of the current de riguer) penchant for an aristocracy is a pathetic and boring attempt by establishment lackeys and losers to entrench their ill-gotten power in the face of ever-growing populist, anti-aristocratic sentiment from both the left and right. That BS flies in democrat-run shi$&oles because they are full of democrats and dems like the arrangement where a few promise the masses trinkets in exchange for massive power and personal wealth for those few.
It is funny that you think that you determine what 10s of millions of otherwise peaceful people have determined they need. The spectre you provide is is merely one example of evidence for the need.
PS: the velocity argument is laughable. A subsonic round in an AR can be an extremely effective choice for ‘self-defense’ and the like.
“Nobody needs an AR-15 for self-defense, just like they don’t need machine guns or RPGs. needs an AR-15 for self-defense, just like they don’t need machine guns or RPGs.”
The 2nd doesn’t protect or allow anything
It just bars the government from infringing on my actions concerning guns
“Nobody needs an AR-15 for self-defense . . .”
Thank you, tyrannical one, for dictating what others do and do not need.
That is the problem with leftists. They think they know better than everyone else and constantly try to tell them what to do, how to live etc.
It is quite delusional on their part. Goes along with other wishful thinking like putting a sign up will stop bad people from behaving badly.
Or passing laws that only impact law abiding citizens will stop criminals from doing bad things.
At the time of the Founding . . . he was responsible for disarming . . .
I don’t buy the premise, but even assuming for argument sake that it’s true, the Second Amendment appears to have been written expressly to prevent that type of “disarming” from continuing.
I’d encourage you to read the history of gun ownership in the US a bit more closely. There has never been any “supervision” of militia firearms as you describe. In fact, there were no laws or restrictions whatsoever on gun ownership until after the Civil War. If you want to read it for yourself, Judge Benitez in California has written at length on this subject in his decisions.
Florida Woman Uses AR-15 To Defend Family During Home Invasion
https://www.cbsnews.com/miami/news/florida-woman-assault-rifle-defend-family-home-invasion/
“A pregnant woman saved her family’s life during a home invasion after she used an AR-15 to fight back against armed burglars.”
You are grossly misinformed. ‘Well regulated’ at the time meant heavily armed. Its an older use of the word but if you have ever seen an old Western film where the posse are called ‘Regulators’ a.k.a. gunmen you get the idea. Besides mentioning the militia is a null argument. In DC vs Heller the majority opinion clearly states that everything before the 2nd comma is a prefatory clause with no legal bearing and everything after is the operative clause that is the law itself. “,the right of the people to keep and bear arms shall not be infringed’ is the only part that has legal consequence. The phrase ‘the people’ is only found in all our founding documents 3 times and all 3 it means everyone. If you insist on the militia argument anyway go read the Federalist Papers- Madison and Hamilton both weighed in on what a militia is. It encompasses teenagers as well so maybe its time 16 year olds can buy AR15s, yes?
“Nobody needs an AR-15 for self-defense,”
Nobody needs, is true. We incarcerate people and remove most of their choices. They survive because no prisoner needs… That is the attitude of the left and the Democrat Party. To them everyone else is a slave.
“Nobody needs an AR-15 for self-defense.”
While it’s true that it’s unlikely that I’d face a home invasion, it could still happen. But if I do face a home invasion, I want the odds to be all in my favor so I own an AR-15 for protection. If one or more intruders are approaching our bedroom at 3:00AM, I do not want a fair fight. I want to win. Period.
Here are the questions I’ve taken into my
1. How many bad guys will there be?
2. What time of day or night will they appear?
3. If more than one, will they enter our house through the same or different entrances?
4. Will they come as a group or from different directions?
5. Will the intruder(s) be on drugs?
6. Will the intruder(s) be armed?
7. How much time will it take for me to perform my OODA loop?
8. How long will it take LE to respond, IF I can call 911 before the SHTF?
9. How far away from me does my nearest neighbor live, the one who might or might not recognize I’m in deep doo-doo??
10. What self-defense procedure should I implement, using what device?
11. What is my age?
12. Am I healthy enough to escape (an) intruder(s) or fend one or more off without a gun?
I appreciate your thoughts on this.
The problem is in Heller the originalist interpretation doesn’t work. So the late Justice Scalia made up a reason to make it work. Weapons such as AR-15’s and other semi-automatics are supposedly protected under the 2nd Amendment is his reasoning that historically weapons that were common at the time of ratification means that weapons that are common today also count. But that’s stretching it quite a bit because semi-automatic or fully automatic weapons did not exist. It’s basically a “living constitution “ approach to interpretation.
Then there’s the problem of with “the people”. At the time of ratification “the people” was commonly used to refer to state governments instead of individuals. When individuals were referred the word “persons” is commonly used. Scalia was taking a few liberties with his interpretation to justify a perverted interpretation of the 2nd amendment.
Semi automatic firearms existed before the constitution. Firearms development was rapidly advancing, Lewis and Clark had a semi auto .46-caliber Girandoni air rifle on their expedition
. Also the “people” is the individual citizen. The founders believed far more in an armed citizenry, than arms in the hands of government agents.
So sorry, but your assessment is incorrect.
“ semi-automatic or fully automatic weapons did not exist.”
Wrong. The first functional machine gun, the Puckle gun, was invented in 1718, fully 64 years BEFORE the second amendment was adopted.
Then there’s the problem of with “the people”. At the time of ratification “the people” was commonly used to refer to state governments instead of individuals.
Which ratified the Constitution? The people of individual States. Because the People are sovereign.
The Bill of Rights was written and sent to the States AFTER the Constitution was presented to the States to ratify. . . by the vote of each citizen. The reason the BoR was written AFTER the States recieved the Constitution for ratification, was because the PEOPLE (not the states) had real concerns this new fangled federal govt abusing the people. The people had been doing fine for over 100 years.
So the framers wrote specific powers the federal govt would not posses. . . protecting the people from the govt.
Good for Illinois. All AR-15 assault weapons should be banned. They reduce human beings to jello. Stop the madness.🕊️
Voice – did you know that 94% of mass shootings take place in gun-free zones? Criminals love those places because they’re less likely to be impeded in committing murder.
If men were angels and all criminals obeyed the law, your reasoning would make more sense. But it should be self-evident that men are not angels and some must be stopped with force when they seek to inflict casualties on innocent people. And it should also be self-evident that the idea of criminals obeying the law is an oxymoron.
OldManFromKS,
Well said.
Leftists live in a fantasy world where all they have to do is click their heels three times and say, “Gun-free zones keep me safe!”
Yup, they live in a la-la land which bears little resemblance to reality. They don’t account for the reality of human nature. Underneath that is the flaw of all leftist politics.
OK. You bloodthirsty people will love this thought: There should be an assault weapons ban in the entire United States. By Congressional legislation. Seems far-fetched, I know. Why do you want weapons of war to be legal? Need them to kill feral pigs, perhaps? Peace love and happiness, everyone.🌈🌻🤩
Voice in the Wilderness
They are great at stomping bugs particularly those in Starbucks hanging out to use wifi
Moses
Moses, if you are referring to moi, I don’t “hang out” at Starbucks. By the way, Senator Bill Cassidy (R-Louisiana) says he needs an AR-15 to kill feral hogs. Was he speaking to his constituents?🌻🤩
Voice in the Wilderness
People who want more gun control are the bloodthirsty ones; they want a situation where criminals are at greater liberty to murder others.
No, citizens who seek to ban assault weapons and support strict background checks are making it more difficult for the criminals. The peace-seekers in this issue are not the problem. The guns are the problem.
On the contrary, the self-appointed “peace seekers” are indeed the problem. They live in la-la land, powered by rainbow unicorns, and they make it easier for criminals to kill in cold blood, because they have no clue about crime and human nature.
If you are serious about reducing gun deaths, then go after the people pulling the trigger.
Bring back stop and frisk.
Do warrant less searches where ever gang members frequent, including their homes and businesses.
Lets strip the criminal of rights, not those exercising their protect rights.
If jello is not, what is the appropriate level of the reduction of human beings trying to rape and murder my family or invade my country and take my rights?
PS: please tell me the number, of the 330,000,000 Americans that were killed via AR-15 (jello’d) last year. While you’re checking, tell us how many kids were less-than-jello’d but still rendered dead via texting last year.
Neil: You just posted that 330,000,000 (million) Americans were killed by AR-15 weapons last year. Census Bureau says the current population of the U.S. is 334,233,854 (that means millions, dear). Only 4 million of us left, huh? Gee. This supports my contention that AR-15 weapons should be banned. Your brain is slowly turning into jello. And comparing death by assault weapons to death by… texting (?!) Is a ridiculous false equivalency.🌻🤩
Nice dodge. You are correct that in your fantasy world, you can ban whatever you like. In the real world, where we have a 2nd amendment and 334,000,000 people, of which basically none will be killed by an AR-15, you have proven nothing except maybe my point.
Is it a false equivalency to compare causes of deaths and your hard-on on stopping them? The lefties seem to really want to do stop people from owning guns, especially one that is owned by 10s of millions that kills basically no one. They spend time, money, and political capital on doing it…why? to save almost no lives per year. They could save many more lives by spending time, money, and political capital on other things that kill way more people, but they ignore those. Why? I’ll give them the benefit of the doubt and say it’s because they are idiots, but the real reason is likely the same reason many of us refuse to give them up.
But yeah, how many of the 334,000,000 Americans were killed by an AR-15 this past year or last or over the past decade or two and compare that number to the 1,000s of kids killed (and killing others) with cell phones while driving. It is a ridiculous comparison, the only thing more ridiculous is which side the left chooses to champion.
If you really wanted to lower the death rate by guns, you’d take every gun away from a democrat in democrat run districts across the country – if you did that, the homicide rate in the US would be lower than many ‘gun-free nations.’ But the dems can’t piss-off their base, can they – MI, PA, etc., would never go dem again.
PS: “please tell me the number, of the 330,000,000 Americans…” doesn’t mean that 330M were killed, btw.
Neil, How did that 330 million number come to sprout in that febrile brain of yours?
“They reduce human beings to jello.”
So can cars, CRT, a B.A. degree. Ban those, too?
The circuit judges are just buying time, hoping that Thomas dies before this goes up to SCOTUS. Ghoulish but true.
I can’t wait to GTFO of this G-dforsaken sh-thole. #IllinoisSucks
I think you mean “President Biden” rather than Bush.
What a shame… we let our court ignore the “well regulated militia” part of it. As tho the 2nd only applies against our own govt or something paranoid. It’s just as important that the people have all available arms at their disposal
. Then again Biden has said more than once..we’d need fighter jets. Against who? Us. Him and he wanted to leave us with simple double barbells off the back porch? Fck that. We need a wel regulated militia. That means every blade of grass has as much fire power as all the sks or whatever may land on our shore.
You must see all the cargo ships full? It’s a shore lander 4sure. Good God get ready.
The 7th Circuit should definitely en banc this case before it goes to Scotus. Given the majority’s questionable reasoning, the plaintiff will undoubtedly request a rehearing en banc.
Yes, I’d expect an en banc petition to be the next step. But the Seventh Circus will likely decline to rehear the case because that’s their way of going along with the Leftist “Principles” of the Seventh Circus.