Interesting, I will have to read that case. I would agree that if the government managed to ban all ranges then it would be infringing on the 2nd amendment. I just don't think a city/state owned and staffed park is mandated by the 2nd amendment. Plus these things are not a hard unbreakable rule, there would certainly be allowances for reasonable suspensions of the park.
i imagine that this is an infringement on the Second Amendment because of the laws that we have in HI and also due to the nature of the C&C of Honolulu and its jurisdiction over the entire island of Oahu.
this is how i see it:
- it is technically illegal to discharge a firearm within a populated area in Hawaii
- the only place that you can legally discharge a firearm is at designated hunting areas and designated ranges (indoor ranges)
- I believe the indoor ranges require a membership to shoot there and they place other restrictions on what can and cannot be done
- it is technically illegal to "hunt" in HI with certain calibers because they are below the 1200 ft lbs minimum muzzle energy (pursuant HAR). One of those calibers is 223 Rem. A 223 Rem 55gr FMJ with a muzzle velocity of 3,000 fps out of a 16" barreled AR-15 is below the minimum muzzle energy. This means that it is illegal for me to plink in designated hunting areas with my 16" barreled AR-15 with the commonly used 55gr FMJ. arguably, this is one of the most common (if not the most common) configurations of the AR-15, which is also the most common centerfire rifle in america.
- it is also illegal to "hunt" with FMJs so i won't be able to shoot my AK or most of my ARs.
- it is also illegal to "hunt" with a 9mm handgun, which means i won't be able to shoot most of my semiauto pistols. also, the case length of a 45 ACP does not meet the minimum "hunting" case length required by HAR.
- rimfire guns such as the 22LR are also prohibited for "hunting"
therefore, if the city does not provide a place to safely maintain proficiency with common legal firearms, then it is an infringement on the Second Amendment right of the residents of Oahu.
in response to your "reasonable suspensions" comment, a court will not look at whether an infringement is "reasonable" when it relates to important constitutional rights. i think that this is something that a lot of people don't really understand. right now the courts have not decided on whether to apply an intermediate scrutiny or strict scrutiny analysis to reviewing cases related to infringements on the Second Amendment. regardless of which scrutiny analysis the court decides to go with, there is little justification for the government to close down the range without a finding that the range would promote a greater spread of COVID-19. the benches are pretty damn far apart, i usually don't give hugs to everyone i see at the range, and people mostly keep their hands to themselves (not touching other people's stuff).
like i said, i would love to make the same argument for the re-opening the municipal golf courses, but maintaining proficiency in golfing is not a protected constitutional right.