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27 buildingâ¦.â283 In Wisconsin, unless a person has a license to carry a concealed weapon, it is unlawful for any person with a firearm to enter âany building owned or leased by the state or any political subdivi- sion of the state,â284 but Wisconsin allows government authorities to post a notice that prohibits the carry- ing of firearms by licensees in public buildings.285 3. States in Which Governmental Units Lack Authority to Post Signs Prohibiting Licensees from Carrying a Firearm in a Public Building Some legislatures have decreed that governmen- tal units lack any authority to post signs prohibiting license holders from carrying a firearm in a public building. In Texas, a state agency or a political sub- division of the State may not prohibit a license holder by the use of a notice or a sign âfrom entering or remaining on a premises or other place owned or leased by the governmental entity unless license holders are prohibited from carrying a handgun on the premises or other placeâ by Section 46.03 of the Texas Penal Code (listing prohibited places includ- ing the sterile area of an airport) or Section 46.03 of the Texas Penal Code (applicable to âunlawful carry- ing of a handgun by a license holderâ).286 To summarize Section V briefly, at least 12 states prohibit the carrying of firearms in public build- ings287 and at least 4 more states permit local gov- ernment authorities to post signs prohibiting firearms in public buildings.288 In some states (e.g., Alabama, Ohio, and Oklahoma), firearms may be prohibited regardless of whether they are carried openly or concealed. VI. FEDERAL AND STATE LAWS ON THE POSSESSION OF A FIREARM IN AIRPORT TERMINALS A. Federal and State Laws that Prohibit Firearms in the Sterile Area of an Airport Under federal law, individuals, except those authorized by law, are prohibited from carrying firearms and other weapons or explosive devices in what is defined as the sterile area of an airport: Sterile area means a portion of an airport defined in the airport security program that provides passengers access to boarding aircraft and to which the access generally is controlled by TSA, or by an aircraft operator under part 1544 of this chapter or a foreign air carrier under part 1546 of this chapter, through the screening of persons and property.289 Some state statutes also describe the sterile area of an airport in a manner similar to or identical to the definition under federal law.290 For example, Idaho law prohibits any person from entering or attempting âto enter any sterile area of an airport, which is a holder of a certificate issued by the fed- eral government or the state of Idaho, while know- ingly carrying on or about his person, or in a bag, case, pouch or other container, a deadly or danger- ous weapon, either concealed or unconcealed.â291 Some state statutes use the terms âsecure areaâ or âsecured areaâ to describe the part of an airport where individuals, except those authorized by law, 283 CAl. penAl Code Â§Â§ 171b(a)(1), (3) (Deering 2015). See CAl. penAl Code Â§ 171b(c) (Deering 2015) (defining the term âstateâ or âlocal public buildingâ). 284 Wis. stAt. Â§Â§ 941.235(1), (2)(e) (2015). 285 Wis. stAt. Â§ 943.13(2)(am) (2015) (providing that a state or local government building may notify âan indi- vidual not to enter or remain in a part of the building while carrying a firearm orâ¦a particular type of fire- armâ if the area is posted with a sign). 286 tex. govât Code Ann. Â§ 411.209(a) (2015). 287 Alabama, Arizona, Arkansas, Connecticut, Delaware, Nebraska, North Carolina, Ohio, Oklahoma, Oregon, Vermont, and Wisconsin. 288 Kansas, Missouri, Montana, and Wisconsin. 289 49 C.F.R. Â§ 1540.5 (2015). Section 1540.5 also defines the term âsecured areaâ to mean a portion of an airport, specified in the airport secu- rity program, in which certain security measures speci- fied in part 1542 of this chapter are carried out. This area is where aircraft operators and foreign air carriers that have a security program under part 1544 or 1546 of this chapter enplane and deplane passengers and sort and load baggage and any adjacent areas that are not separated by adequate security measures. 290 Ariz. rev. stAt. Â§ 13-3119(B)(4) (LexisNexis 2015) (but excluding general aviation areas); CAl. penAl Code Â§Â§ 171.5(b), (c)(1), (12) (Deering 2015) (âIt is unlawful for any person to knowingly possess, within any sterile area of an airport or a passenger vessel terminal, any of the items listed in subdivision (c),â such as a firearm or ammu- nition); 740 mAss. Code regs. 30.04(2) (LexisNexis 2015) (stating that no person other than federal or state law enforcement officers and other designated personnel âshall possess either on the individualâs person or in her accessible Property within a Sterile Area of an Airport, any item or material prohibited by federal transportation security regulationsâ¦.â); miCh. Comp. lAWs serv. Â§ 259.80(f)(1) (LexisNexis 2015) (âAn individual shall not possess, carry, or attempt to possess or carry [a firearm or other dangerous weapons or devices] in a sterile area of a commercial airport.â); mo. rev. stAt. Â§ 571.107(1)(8) (2015) (stating that âneither a licensee nor an out-of-state licensee may knowingly carry a concealed weapon, a weapon that is not concealed, or a firearm that is not a weapon inâ¦[a] place beyond a security checkpoint in an airportâ); or. rev. stAt. Â§ 164.885(2)(a) (2015); Wis. stAt. Â§ 175.60(16)(a)(8) (2015) (stating that â[e]xcept as pro- vided in par. (b), neither a licensee nor an out-of-state licensee may knowingly carry a concealed weapon, a weapon that is not concealed, or a firearm that is not a weaponâ¦beyond a security checkpoint in an airportâ). 291 idAho Code Ann. Â§ 18-7503(1) (2015).
28 are prohibited from carrying firearms and other weapons or explosive devices.292 There are state statutes that specifically prohibit a person, including one having a license to carry a con- cealed weapon, from entering the sterile area of an airport.293 For example, a Missouri statute provides: No concealed carry permit issued pursuant to [Mo. Rev. Stat. Â§Â§] 571.101 to 571.121, valid concealed carry endorsement issued prior to August 28, 2013, or a concealed carry endorse- ment or permit issued by another state or political subdivision of another state shall authorize any person to carry concealed firearms intoâ¦[a]ny area of an airport to which access is con- trolled by the inspection of persons and propertyâ¦.294 Of course individuals, nevertheless, may present themselves at airport screening checkpoints while pos- sessing a firearmâfor example, in a carry-on bagâbut claim as a defense that they had forgotten about the firearm. The question has arisen as to whether to obtain a conviction, the State has to prove that the defendant knowingly or intentionally possessed a firearm in violation of a statute. Minnesota requires a permit to carry a handgun. Section 624.714, subdivi- sion 1a, of the Minnesota Statutes provides in part that [a] person, other than a peace officer, as defined in section 626.84, subdivision 1, who carries, holds, or possesses a pis- tol in a motor vehicle, snowmobile, or boat, or on or about the personâs clothes or the person, or otherwise in posses- sion or control in a public place, as defined in section 624.7181, subdivision 1, paragraph (c), without first having obtained a permit to carry the pistol is guilty of a gross mis- demeanor. A person who is convicted a second or subse- quent time is guilty of a felony. Although the case did not involve possession of a firearm at an airport screening checkpoint, in State v. Ndikum,295 the issue was whether the defendantâs knowledge or intent to possess a pistol in violation of Minnesota Statutes Section 624.714, subdivision 1a, was an element that the State had to prove to obtain a conviction for the defendantâs violation of the stat- ute. The court noted that Section 624.714 includes several exceptions to the permit requirement for public gun possession, exceptions that âacknowledge that possessing guns in public is not strictly regu- lated.â296 The court held: Our examination of section 624.714 leads us to conclude that the statute does not treat guns as highly dangerous devices and does not put gun owners on notice of stringent regulation. Section 624.714, subdivision 1a, is not a public welfare statute designed to strictly regulate a highly-dan- gerous device and, therefore, we conclude that mens rea was not dispensed with by the Legislature. â¦Thus, to obtain a conviction, the State was required to prove that Ndikum knew he possessed the pistol.297 The Ndikum decision may be compared to cases involving Metropolitan Airports Commission (MAC) Ordinance Number 91. Section 6 of the ordinance states: âNo [p]erson shall place a firearm, explosive device, knife or other FAA prohibited item that could be used as a weapon onto inspection equipment at a Security Screening Area without first declaring such item.â A conviction is punishable âwithin the param- eters of the maximum penalty for misdemeanors set forth in section 609.03 of the Minnesota Statutes as amended.â298 A state court in Minnesotaâs fourth judicial district has ruled that the State does not have to prove that a defendant knowingly or inten- tionally meant to enter the sterile area of an airport while possessing a firearm. In Minnesota v. Rostvold,299 the defendant was charged with violating Section 6.5 of MAC Ordi- nance 91. In finding that the State did not have to 292 Ariz. rev. stAt. Â§ 13-3119(D)(2) (LexisNexis 2015) (defining âsecured areaâ of an airport); Ark. Code Ann. Â§ 5-73-120(c)(4)(A) (2015) (unlawful for a person intention- ally to carry or possess or exercise control âover a deadly weapon in a secured area of an airportâ); tenn. Code Ann. Â§Â§ 39-17-109(a), (b) (2015) (defining the term âsecure areaâ to be âan area to which access is controlled by the inspection of persons and property in accordance with an approved security programâ); tex. penAl Code Ann. Â§ 46.03(a)(5) (2015) (prohibiting the possession of a firearm in the secured area of an airport); tex. penAl Code Ann. Â§ 46.03(c)(2) (2015) (defining the term âsecured areaâ); utAh Code Ann. Â§Â§ 76-10- 528(1), (2)(a) (LexisNexis 2015) (defining the term âairport authorityâ and prohibiting the carrying of a concealed fire- arm, including by one licensed to carry a concealed firearm, within the secure area of an airport); utAh Code Ann. Â§ 53-5- 710 (LexisNexis 2015) (prohibiting a person with a permit to carry a concealed firearm âin any airport secure areaâ). See also Response of George Bush Intercontinental Airport (stating that tex. penAl Code Â§ 46.03 prohibits firearms in the âsecured areaâ of an airport). 293 LA. rev. stAt. Ann. Â§ 40:1379.3(N) (2015) (stating that a concealed handgun permit does not authorize a per- son to carry a handgun into any portion of an airport facil- ity in which the carrying of firearms is prohibited by fed- eral law); ky. rev. stAt. Ann. Â§ 237.110(16)(g) (LexisNexis 2015) (âExcept as provided in KRS 527.020, no license issued pursuant to this section shall authorize any person to carry a concealed firearm intoâ¦[a]n area of an airport to which access is controlled by the inspection of persons and propertyâ¦.â); utAh Code Ann. Â§ 76-10529(2)(a) (LexisNexis 2015) (âWithin a secure area of an airport established pursuant to this section, a person, including a person licensed to carry a concealed firearm under [the] Concealed Weapon Act, is guilty ofâ¦a class A misde- meanor if the person knowingly or intentionally possesses any dangerous weapon or firearmâ¦.â); Wis. stAt. Â§ 175.60(a)(8) (2015) (licensee not authorized to carry fire- arm beyond security checkpoint in an airport). 294 mo. rev. stAt. Â§ 571(1)(8) (2015). See also or. rev. stAt. Â§ 164.885(2)(a) (2015). 295 815 N.W.2d 816 (Minn. 2012). 296 Id. at 821. 297 Id. at 822. 298 metro. Airports Commân ordinAnCe 91, Â§ 6.5. 299 No. 27-CR-12-14340 (Unpub.) (4th Jud. Dist. Ct., Hennepin Cnty., Oct. 1, 2012).
29 prove the defendantâs knowledge or intent for a con- viction, the district court distinguished the Ndikum case. The court held that Section 6.5 of MAC Ordi- nance 91 is a public welfare and safety ordinance that strictly prohibits all citizens, law-abiding or otherwise, from placing a handgun onto security inspection equipment âwithout first declaring such item.â300 As a public safety and welfare regulation, the ordinance does not require proof of the defen- dantâs mens rea; thus, the State was not required to prove the defendantâs knowledge or intent to obtain a conviction for violating the ordinance.301 As for general aviation terminals and facilities and secure areas, an Arkansas law excludes general aviation: âGeneral aviation areas [are] not included in the security identification display area or sterile area as defined in the airport security program approved by the transportation security administra- tion.â302 The rules of Portland International Airport in Oregon prohibit anyone other than authorized personnel âto possess any firearms or explosives within a Restricted Areaâ; however, the foregoing section âdoes not apply to persons lawfully trans- porting or carrying firearms or deadly weapons in the General Aviation Area.â303 In contrast, the Massachusetts regulations provide that other than authorized, designated officials, â[n]o personâ¦shall carry loaded or otherwise operational Firearms or explosives on the Airport,â and that [a]ll persons shall, promptly upon entering the passenger terminal or General Aviation Terminal, as the case may be, deliver any unloaded Firearms and ammunition, as they are carrying and licensed to carry under Massachusetts law to the appropriate Air Carrier agent for transport in the hold of the aircraft, in the case of commercial flights, or directly to the aircraft, in the case of general aviation aircraft.304 Possibly some individuals forget that they have a firearm when they arrive at an airport security checkpoint, or they are under the mistaken impres- sion that a permit to carry a firearm or a permit to carry a concealed firearm allows them to carry a firearm into the sterile area of an airport. Some state legislatures have addressed the issue by stat- ute. For example, Georgia has enacted a safe harbor provision that allows a person who arrives at a secu- rity screening checkpoint at the entry to the sterile area possessing a firearm to retrieve his or her fire- arm and leave the area without being charged with a criminal offense; however, the safe harbor provi- sion only applies to a person who has a license to carry a firearm.305 In contrast to the Georgia statute, an amend- ment to Section 46.03 of the Texas Penal Code pro- vides that it is unlawful for a person âintentionally, knowingly, or recklesslyâ to possess or go in or âinto a secured area of an airportâ with a firearm or other prohibited weapon.306 If a person violates the law, it will no longer be a defense to prosecution that the offender was licensed to carry a handgun.307 As discussed in Section XIV.B, TSA may take administrative action to assess a civil penalty against an individual who attempts to pass through security while possessing a firearm. B. State Laws that Prohibit or Restrict the Open Carrying of a Firearm State laws vary regarding whether firearms may be carried openly. Unless restricted by stat- ute, the laws apply statewide, including to air- ports. It appears that 31 states permit a handgun to be carried openly without a license or permit; 5 states (California, Florida, Illinois, New York, and South Carolina) and the District of Columbia ban the open carrying of a handgun; and 6 states (California, Florida, Illinois, Massachusetts, Minnesota, and New Jersey) and the District of Columbia prohibit the open carrying of long guns.308 Fifteen states require a license or permit to carry a firearm openly: Connecticut, Georgia, Hawaii, Indiana, Iowa, Maryland, Massachusetts, Minnesota, Missouri, New Jersey, Oklahoma, Rhode Island, Tennessee, Texas, and Utah.309 Among the states that allow the open carrying of a firearm, there are exceptions for schools, state- owned businesses, places where alcohol is served, and public transportation.310 300 metro. Airports Commân ordinAnCe 91, Â§ 6.5. 301 Likewise, in Minnesota v. Haskins, No. 27-CR-12- 15902 (Unpub.) (4th Jud. Dist. Ct., Hennepin Cnty., Oct. 1, 2012), the district court held that metro. Airports Commân ordinAnCe 91, Â§ 6.5, as a public welfare and safety regula- tion did not require proof of the defendantâs knowledge or intent to obtain a conviction for the defendantâs failure to declare a firearm at an airport screening area. 302 Ark. Code Ann. Â§ 5-73-120(c)(4) (2015). See also Ariz. rev. stAt. Â§ 13-3119(B)(4) (LexisNexis 2015) (excluding general aviation areas). 303 Portland International Airport Rules 33, port of portlAnd (2015), http://www.portofportland.com/pdfpop/ PDX_Rules.pdf. 304 740 mAss. Code regs. Â§ 30.04(1) (LexisNexis 2015) (emphasis added). 305 gA. Code Ann. Â§ 16-11-130.2(a) (2015). See also gA. Code Ann. Â§ 16-12-127 (2015). 306 tex. penAl Code Ann. Â§ 46.03(a)(1)(B)(5) (2015). See also tex. penAl Code Ann. Â§ 46.03 (effective Aug. 1, 2016). 307 Compare tex. penAl Code Ann. Â§ 46.03(f) (2015), with tex. penAl Code Ann. Â§Â§ 46.03(e), (e-1), (f) (2015). 308 Open Carrying Policy Summary, lAW Center to pre- vent gun violenCe (Aug. 21, 2015), http://smartgunlaws. org/open-carrying-policy-summary/#footnote_49_5940. 309 Id. 310 Id.
30 C. State Laws Specifically Prohibiting Firearms in Airport Terminals and on Other Airport Property Several states by statute have prohibited the pos- session of firearms anywhere in airport terminals, including areas for ticketing and baggage claim, with some states also prohibiting them on other air- port property. In Alaska, although there is authority that Alaska prohibits firearms only in the sterile area of airports,311 there is a provision in the Alaska Administrative Code that applies directly to termi- nal buildings of airports: (a) A person may not carry a firearm or prohibited weapon in a department-operated terminal building or restricted area except in compliance with any other applicable law and (1) as authorized by this section; (2) as necessary to fulfill a legal requirement; or (3) as specifically permitted by law. (b) Before boarding an air carrier aircraft, a passenger transporting a firearm shall check the firearm, unloaded and encased in a closed container designed for transporting firearms, as or within luggage and notify the air carrier that the luggage contains a firearm.312 In Arkansas, a license to carry a concealed hand- gun does not allow a person âto carry a concealed handgunâ¦[i]nside the passenger terminal of any airport, exceptâ¦if the firearm is encased for ship- ment for purposes of checking the firearm as bag- gage to be lawfully transported on any aircraftâ¦.â313 An interesting statutory provision in Arkansas is that it is permissible for a person to carry a weapon if â[t]he person isâ¦upon a journey, unless the jour- ney is through a commercial airportâ¦.â314 The Arkansas attorney general has issued an opinion stating that although the term âjourneyâ is ambigu- ous, the statute applies when a person is in the pro- cess of traveling by vehicle outside his or her county; moreover, âthe journey exception only applies while the handgun remains in the vehicle.â315 If a person takes the handgun out of the vehicle, the âjourney exceptionâ no longer applies, meaning that the person would be âcommitting the offense of âcarry- ing a weaponââ in violation of Arkansas law.316 Connecticut law states, as part of a statute appli- cable to a permit to carry a pistol or revolver, that a permit does not authorize anyone to carry a pistol or revolver on any premises where the person who owns or controls the premises has posted a sign pro- hibiting firearms at the prescribed distance from the entrance and in the form required by the statute.317 In Florida, the statute is quite explicit that fire- arms are prohibited in airports, including by private individuals licensed to carry a firearm either openly or in a concealed manner: A license issued under this section does not authorize any person to openly carry a handgun or carry a concealed weapon or firearm intoâ¦the passenger terminal and sterile area of any airport, provided that no person shall be prohib- ited from carrying any legal firearm into the terminal, which firearm is encased for shipment for purposes of checking such firearm as baggage to be lawfully transported on any aircraftâ¦.318 In Iowa, notwithstanding state law that limits local regulation of firearms,319 a local ordinance bans firearms and other weapons âon property under the jurisdiction of the [Des Moines Airport] Authority, including the parking garages and lots.â320 The stateâs attorney general issued an opinion in 2003 stating that, notwithstanding the state preemption statute, there is a lawful basis for the local ordinance: Iowa courts would likely construe the preemption provision contained in Iowa Code section 724.28 narrowly and would recognize the authority of a city to exercise its home rule power to place restrictions upon the possession of weapons which apply only to buildings owned or directly controlled by the city. Therefore, we believe that the City of West Burlington could enforce its ordinance against a person who is authorized by Iowa Code section 724.4 to carry a fire- arm and may prohibit a nonprofessional person from pos- sessing a firearm within a municipal building, even though 311 Thomson, supra note 265 (citing AlAskA stAt. Â§Â§ 29.35.145, 29.35.145(a)(4), Â§ 29.35.145(e)(2)). 312 AlAskA Admin. Code tit. 17, Â§ 42.065(a)(3) (2015) (emphasis added). See also, id., Â§ 42.005 (2015). 313 Ark. Code Ann. Â§ 5-73-306(15) (2015). 314 Ark. Code Ann. Â§Â§ 5-73-120(a), (c)(4) (2015) (adding a proviso that possession is unlawful when a person is pre- senting a firearm at an airport security checkpoint or the firearm is in the personâs checked baggage âand is not a lawfully declared weaponâ). 315 Ark. Attây Gen. Op. No. 2015-064, supra note 157, at 7. 316 Id. See also John Thomas Shepherd, Comment, Who is the Arkansas Traveler: Analyzing Arkansasâs âJourneyâ Exception to the Offense of Carrying a Weapon, 66 Ark. l. rev. 463, 467 (2013) (âBecause this statutory provision is ambiguous as to what journey means, determining the legislatureâs intent through the plain language of the stat- ute is not helpful.â) 317 Conn. gen. stAt. Â§ 29-28(e) (2015). 318 flA. stAt. Ann. Â§ 790.06(12)(a)(14) (LexisNexis 2015) (emphasis added). 319 ioWA Code Â§ 724.28 (2015) (prohibiting political subdi- vision of the State from enacting an ordinance regulating the ownership, possession, legal transfer, lawful transpor- tation, registration, or licensing of firearms when the own- ership, possession, transfer, or transportation is otherwise lawful under the laws of the State of Iowa). 320 Des Moines Airport Authority Rules & Regulations, Rule 3-24, at 14 (June 9, 2015), http://www.dsmairport.com/ webres/File/about-the-airport/employment/Rules%20 and%20Regulations/Rules%20%20Regulations%20 06092015%20FINAL.pdf.
31 the person has a valid permit to carry the firearm and car- ries it in compliance both with Iowa Code section 724.4(4)(i) and with any limitations specified in the permit.321 In Maine, the rules and regulations applicable to Augusta State Airport provide that â[n]o person, except those duly authorized by law, shall carry any weapon, firearm, or explosive on [an] airport, except encased sporting guns for air shipment.â322 Maryland law provides that weapons are prohibited in airports, âexcept those that are properly packaged for ship- ment.â323 In Maryland, no weapons or explosives may be carried in or on the Baltimore/Washington International Thurgood Marshall Airport.324 Massachusetts allows an airport commission âto adopt rules and regulations for the use of municipal airports or for the safety of the public upon or beyond the limits of airports under its control, whether such airport facilities are within or without the territorial limits of the city or town,â subject to the approval of the Massachusetts Aeronautics Commission.325 Massachusetts also has created a special security zone for Bostonâs Logan Airport in which firearms, as well as other weapons and explosives, are prohib- ited.326 Anyone other than authorized personnel pos- sessing a firearm at Logan Airport shall, promptly upon entering the passenger terminal or General Aviation Terminal, as the case may be, deliver any unloaded Firearms and ammunition, as they are carrying and licensed to carry under Massachusetts law to the appropriate Air Carrier agent for transport in the hold of the aircraft, in the case of commercial flights, or directly to the aircraft, in the case of general aviation aircraft.327 Under Mississippi law, although a person may carry a legal firearm into an airport terminal if the firearm is encased for shipment for checking as baggage on an aircraft, â[n]o license issued pursuant to this section [a license to carry a concealed pistol or revolver] shall authorize any person to carry a stun gun, concealed pistol or revolverâ¦inside the passenger terminal of any airport.â328 Nevada prohibits individuals who have a permit from carrying a concealed weapon âon the premises of a public building that is located on the property of a public airport.â329 A local ordinance in North Carolina makes it unlawful to carry a danger- ous weapon in the Charlotte Douglas International Airport except to ship it âby air in compliance with fed- eral and state laws and regulations.â330 An Ohio statute is somewhat opaque when read in its entirety, but it seems to authorize the board of trustees of a regional airport authority, chief administrative officer of an airport facility, or other person in charge of an airport facility to post a sign at a conspicuous location at each airport facility under that personâs control stating: ââUnless other- wise authorized by law, pursuant to the Ohio Revised Code, no person shall knowingly possess, have under the personâs control, convey, or attempt to convey a deadly weapon or dangerous ordnance onto these premises.ââ331 As noted in Section VI.E, the Columbus Regional Airport Authority in Ohio 321 Iowa Attây Gen. Op. No. 03-4-1, at 5 (unnumbered pages) (Apr. 7, 2003), available at http://www.handgunlaw. us/documents/agopinions/IAAGOp03_4_1.pdf. 322 49 C.F.R. Â§ 1540.5 (2015). Section 1540.5 also defines the me. Code r., Department of Transportation, sub- agency 229, Rules and Regulations for the Use of the Augusta State Airport, Â§ 400.08 (LexisNexis 2015). See also md. Code regs. Â§ 11.03.01.09.C(1) (2015) (stating that with certain exceptions â[w]eapons, except those properly packaged for shipment, are prohibitedâ¦.â); 740 mAss. Code regs. Â§ 30.04(1) (LexisNexis 2015) (providing in part that â[n]o person except federal or state law enforcement offi- cers [and other designated agencies and personnel] who are authorized and validly licensed to carry Firearms, ammunition and explosives in Massachusetts, shall carry loaded or otherwise operational Firearms or explosives on the Airportâ); N.Y. penAl lAW Â§ 265.01 (Consol. 2015) (âA person is guilty of criminal possession of a weapon in the fourth degree whenâ¦[h]e or she possesses any firearmâ¦.â). See Allegheny County. pA., ordinAnCe Â§ 705-39 (2015): A. No person, except law enforcement officers, post office and custom officials, or members of the Armed Forces of the United States on active duty, shall carry any weapon, firearm, explosive or inflammable material on the airport premises except by specific direction of the Director, the Superintendent of Police or their designees. B. No person shall transport any weapon or firearm except when it is properly enclosed for shipment and is not in the personâs manual possession. See also metro WAsh. regulAtions Â§ 8.4(1) (2015): No person may possess a dangerous weapon within or bring any dangerous weapon into the Airportsâ terminals or the airfields or any building that opens onto the airfield on which signs are posted so as to give reasonable notice to the public unless: (a) the person is a passenger of an air- line and possesses the weapon in one of the Airportsâ ter- minals for the sole purposes of (i) presenting such weapon to U.S. Customs agents in advance of an international flight, (ii) checking such weapon with his luggage, or (iii) retrieving such weapon from the baggage claim areaâ¦. 323 md. Code regs. Â§Â§ 11.03.01.09(B)(3), (C) (2015) (applicable to Baltimore Washington International Thurgood Marshall Airport), available at http://www.dsd. state.md.us/COMAR/SubtitleSearch.aspx?search=11.03.01. 324 740 mAss. Code regs. Â§Â§ 30.04(1), 30.05 (2015). 325 mAss. Ann. lAWs ch. 90, Â§ 51J (LexisNexis 2015). 326 mAss. Ann. lAWs ch. 90, Â§Â§ 61(a), (b) (LexisNexis 2015). 327 740 mAss. Code regs. Â§ 30.04(1) (LexisNexis 2015). 328 miss. Code Ann. Â§ 45-9-101(13) (2015). 329 nev. rev. stAt. Ann. Â§ 202.3673(2) (LexisNexis 2015). 330 ChArlotte, n.C. ordinAnCe Â§Â§ 15-14 (b), (c)(3) (2003). 331 ohio rev. Code Ann. Â§ 2923.1212(A)(5) (LexisNexis 2015). See also ohio rev. Code Ann. Â§ 2923.12(F) (LexisNexis 2015) (stating that the carrying of a concealed weapon aboard an aircraft is a felony of the third degree).
32 prohibits firearms anywhere in the terminal of three airports subject to its authority. In Pennsylvania, an Allegheny County (Pittsburgh being the county seat) ordinance states that other than authorized, designated personnel, â[n]o personâ¦ shall carry any weapon, firearm, explosive or inflam- mable material on the airport premises,â except by those designated in the ordinance.332 A Virginia statute very clearly prohibits private individuals from carrying firearms in airports in Virginia. In Virginia, it is unlawful for any person to possess or transport into any air carrier airport terminal in the Commonwealth any (i) gun or other weapon designed or intended to propel a missile or projec- tile of any kind, (ii) frame, receiver, muffler, silencer, missile, projectile or ammunition designed for use with a dangerous weapon, and (iii) any other dangerous weapon, including explosives, stun weapons as defined in Â§ 18.2-308.1, and those weapons specified in subsection A of Â§ 18.2-308.333 Passengers may transport a firearm âfor the sole purposesâ¦of (i) presenting such firearm, weapon, or ammunition to U.S. Customs agents in advance of an international flight in order to comply with fed- eral law, (ii) checking such firearm, weapon, or ammunition with his luggage, or (iii) retrieving such firearm, weapon, or ammunition from the baggage claim area.â334 In 2014, the Metropolitan Washington Airports Authority that administers Ronald Reagan Wash- ington National Airport and Washington Dulles International Airport, both located in Virginia, decided that travelers and other airport visitors may âcarry guns, knives and other weapons as long as they keep them out of terminals and other build- ings that access airfields.â335 As a result, parking lots at the airports are not off-limits to firearms as long as the person possessing or transporting a firearm complies with other Virginia laws. D. Airport Responses on the Legality of Carrying Firearms in the Nonsterile Area of an Airport Twenty airports responding to the survey reported that private individuals are allowed to carry firearms in the nonsterile area of the airport,336 whereas 10 airports stated that there are laws in their state that prohibit the open carrying of fire- arms in the nonsterile area of an airport terminal or on airport property.337 George Bush Intercontinental Airport in Houston reported that it is illegal to carry a handgun in public in Texas without a permit,338 but that state law pro- hibits the City of Houston from regulating âthe trans- fer, private ownership, keeping, transportation, licensing, or registration of firearms, air guns, ammu- nition, or firearm or air gun supplies.â339 Furthermore, the City of Houston âcannot use the Texas criminal trespass statute to prevent a concealed handgun license holder from entering government property.â340 The MinneapolisâSt. Paul International Airportâs 332 Allegheny County. pA., ordinAnCe Â§ 705-39 (2015) (stating also that â[n]o person shall transport any weapon or firearm except when it is properly enclosed for ship- ment and is not in the personâs manual possessionâ). As for the Philadelphia International Airport, see Philadelphia International Airport Rules and Regulations Â§ 2(D), at 2-1 (July 2014), available at http://www.phl.org/Business/ Pages/Airport-Rules-and-Regulations-.aspx. 333 vA. Code Ann. Â§ 18.2-287.01 (2015) (emphasis added). The section further provides: Any such weapon shall be subject to seizure by a law- enforcement officer. A violation of this section is punish- able as a Class 1 misdemeanor. Any weapon possessed or transported in violation of this section shall be forfeited to the Commonwealth and disposed of as provided in Â§ 19.2-386.28. 334 vA. Code Ann. Â§ 18.2-287.01 (2015). 335 Steven Ginsberg & Karin Brulliard, Weapons Rules Eased at Dulles and National, WAsh. post, Oct.. 7, 2004, http://www.washingtonpost.com/wp-dyn/articles/A13174- 2004Oct6.html. 336 Responses of Albuquerque International Sunport Air- port, N.M.; AustinâBergstrom International Airport, Tex.; Blue Grass Airport, Lexington, Ky.; Casper/Natrona County International Airport, Wyo.; Clinton National/Adams Field Airport, Little Rock, Ark.; Dallas Fort Worth International Airport (stating only with a permit), Tex.; General Mitchell International Airport, Milwaukee, Wis.; George Bush Inter- continental/Houston Airport, Tex.; Gerald R. Ford Interna- tional Airport, Grand Rapids, Mich.; Huntsville Interna- tionalâCarl T. Jones Field, Ala.; LaGuardia Airport, N.Y.; Lincoln AirportâLincoln Airport Authority, Neb.; Louisville InternationalâStandiford Field, Ky.; Memphis Interna- tional Airport, Tenn.; MinneapolisâSt. Paul International/ World-Chamberlain Airport, Minn.; Portsmouth Interna- tional Airport, N.H.; Theodore Francis Green State Air- portâRhode Island Airport Corp.; Joe Foss Field, Sioux Falls, S.D.; Spokane International Airport, Wash.; Tucson International AirportâTucson Airport Authority, Ariz. 337 Albuquerque International Sunport Airport, N.M.; Bangor International Airport, Me.; Blue Grass Airport, Lexington, Ky. (citing ky. rev. stAt. Ann. Â§ 183.8811); Dallas Fort Worth International Airport, Tex. (stating without a permit); Eppley Airfield Airport (Omaha), Neb. (citing neB. rev. stAt. Ann. Â§ 69-2441); Bismarck Municipal Airport, N.D.; George Bush Intercontinental/Houston Airport, Tex. (stating that the answer is yes until Jan. 1, 2016, then no); Grand Forks International Airport, N.D.; Nashville International Airport, Tenn. (citing tenn. Code Ann. Â§ 39-17-1359); Theodore Francis Green State Air- portâRhode Island Airport Corp. 338 Response of George Bush Intercontinental/Houston Airport, Tex. (citing tex. penAl Code Ann. Â§ 46.02). See also tex. penAl Code Ann. Â§ 46.02 (2016). 339 Id. (citing houston, tex., loCAl govât Code Â§ 229.001(a)). 340 Id. (citing tex. penAl Code Ann. Â§ 30.06(e)).
33 may carry, possess, use or store any Firearm, ammunition, explosive or destructive device or other deadly Weapons in any form inside the Passenger Terminal or on Airport prop- erty [except when] properly encased for shipmentâ¦as cargo or checked baggage and actually delivered to an airline before the Person approaches the security checkpoint.346 Clinton National/Adams Field Airport in Little Rock, Arkansas, cited Section 305 of its rules that prohibit firearms inside the terminal building âunless carried by sworn law enforcement officers or packaged for shipment via aircraft in compliance with federal regulations.â347 All persons not autho- rized to have a firearm in the terminal are directed to âsurrender all such firearms, explosives or similar inflammable materials in their possession upon demand to the Airport Police or remove same from the Airport.â Several airports that responded to the survey also advised that they have posted signs prohibiting firearms. Pursuant to Section 69-2441 of the Nebraska Revised Statutes, relating to a permit to carry a concealed handgun, and Section 3.9 of its rules and regulations, the Lincoln Airport Authority has posted signs banning the carrying of concealed weapons in the airport.348 In addition to the airports that responded to the survey, other airport rules and regulations prohibit- ing firearms were located for the digest. The rules of the Columbus Regional Airport Authority in Ohio, applicable to Port Columbus International Airport, Rickenbacker International Airport, and Bolton Field Airport, prohibit firearms anywhere in the ter- minal, except for authorized persons: A. No person, except law enforcement officers with verifi- able identification and such other persons authorized by the President & CEO, or designee, shall carry a firearm or weapon into or any terminal, unless the firearm or weapon is encased for shipment for the purpose of checking such firearm or weapon with an airline to be lawfully trans- ported on an aircraft. B. Other than as authorized by federal or state law, or as specified in Section 3.9(A) of these Rules, no person shall carry, bring or otherwise transport, a firearm, deadly weapon, dangerous ordnance or other weapon as defined in Sections 2923.11 to 2923.24, Ohio Revised Code, anywhere on Authority premisesâ¦.349 response similarly noted that because Section 624.714, subdivision 23 of the Minnesota Statutes âhas taken away the ability of Minnesota government agencies or units to regulate the carrying and permitting of pis- tolsâ¦only federal law prohibits where a pistol may be carried on airport propertyâ in Minnesota.341 E. Airport Rules and Regulations Prohibiting Firearms in Airport Terminals or on Other Airport Property Twelve airports that responded to the survey reported that the airport or airport authority has rules regulating the possession of firearms by pri- vate individuals in the nonsterile area of an airport terminal or on airport property,342 whereas 16 air- ports reported that they do not.343 Based on the sur- vey responses and other research on selected airport rules, regulations, or ordinances, there is at least one airport in 16 states that prohibits firearms in the air- port terminal and on other airport property.344 Blue Grass Airport in Lexington, Kentucky, cited Section 14 of the LexingtonâFayette Urban County Airport Board Rules and Regulations.345 Other than authorized, designated personnel no one 341 Response of MinneapolisâSt. Paul International Airport. 342 Responses of AustinâBergstrom International Airport, Tex.; Bangor International Airport, Me.; Bismarck Municipal Airport, N.D. (citing N.D. Cent. Code Â§ 62.1-02-05); Blue Grass Airport, Lexington, Ky.; Clinton National/Adams Field Airport, Little Rock, Ark.; Columbia Metropolitan Airport, S.C.; Detroit Metropolitan Wayne County Airport, Mich.; Eppley Airfield Airport (Omaha), Neb. (citing neB. rev. stAt. Ann. Â§ 69-2441); General Mitchell International Airport, Milwaukee, Wis.; Grand Forks International Airport, N.D.; Lincoln AirportâLincoln Airport Authority, Neb.; Nashville International Airport, Tenn. 343 Responses of Albuquerque International Sunport Air- port, N.M.; Casper/Natrona County International Airport, Wyo.; Dallas Fort Worth International Airport, Tex.; George Bush Intercontinental/Houston Airport, Tex.; Gerald R. Ford International Airport, Grand Rapids, Mich.; Hunts- ville InternationalâCarl T. Jones Field, Ala.; LaGuardia Airport, N.Y.; Louisville InternationalâStandiford Field, Ky.; Memphis International Airport, Tenn.; Minneapolisâ St. Paul International/WorldâChamberlain Airport, Minn.; Portsmouth International Airport, N.H.; Theodore Francis Green State AirportâRhode Island Airport Corp.; San Francisco International Airport, Cal.; Joe Foss Field, Sioux Falls, S.D.; Spokane International Airport, Wash.; Tucson International AirportâTucson Airport Authority, Ariz. 344 Arkansas, California, Georgia (HartsfieldâJackson Atlanta International Airport), Kentucky, Maine (Augusta State Airport), Michigan, Nebraska, North Dakota, Ohio, Oregon, Pennsylvania, Port Authority of New York and New Jersey, North Dakota, South Carolina, Washington, and Wisconsin. 345 lexington-fAyette urBAn Cnty. Airport Bd. rules And regulAtions (Sept. 26, 2012), available at https:// www.bluegrassairport.com/documents/lfucabRules andRegs-3.pdf. 346 Id. at 21. 347 Response of Clinton National/Adams Field Airport, Little Rock, Ark. 348 Responses of Lincoln AirportâLincoln Airport Author- ity, Neb., and General Mitchell International Airport, Wis. (reporting that the airport has posted signs that comply with the state statute to prohibit weapons). 349 rules of the ColumBus regâl Airport Auth. Â§ 3.9 (July 20, 2009), available at http://columbusairports.com/ files/doing-business/pdfs/craa-rules1.pdf.
34 [Airport Operations Area]â¦.â359 John F. Kennedy International Airport; LaGuardia Airport; Newark Liberty International Airport; Stewart International Airport (New Windsor, New York); and Teterboro Air- port (New Jersey) are subject to the jurisdiction of the Port Authority of New York and New Jersey.360 A Wayne County Airport Authority (WCAA) ordi- nance that applies to the Detroit Metropolitan Air- port bans dangerous weapons in any area of the airport, such as airport buildings, airport terminals, airfields, parking lots, aircraft, vehicles using the airport, and any building or gate that opens onto the airfield.361 The WCAA has declared that â[t]he prohi- bition of dangerous weapons at the Airportâ¦is nec- essary to fulfill the Airport Authorityâs obligations under federal law to provide for the safety and secu- rity of persons and property on Aircraft operating in air transportation or intrastate air.â362 Consistent with the law of Virginia discussed in Section VI.C, the regulations of MWAA, applicable to Ronald Reagan Washington National Airport and Washington Dulles International Airport, both located in Virginia, prohibit any dangerous weapons in the airport terminals âor the airfields or any building that opens onto the airfield on which signs are postedâ that give reasonable notice to the public that weapons are prohibited.363 The only weapon that MWAA allows is one that an individual will be presenting to a customs agent prior to an interna- tional flight; is checking in his or her luggage in the manner required; or is collecting in a baggage claim area.364 A weapon may be brought to the airport only if it is packaged for shipment.365 A weapon that is a firearm must be unloaded and locked in a container for which only the individual has the key.366 Other airports that have similar prohibitory fire- arms policies are Columbia Metropolitan Airport in South Carolina,367 Grand Forks International On July 1, 2008, the HartsfieldâJackson Atlanta International Airport announced that the airport is a âgun-free zone.â350 The announcement was in response to Georgiaâs enactment of House Bill 89 that allows Georgia citizens who have firearm licenses to bring a concealed weapon aboard public transportation, into restaurants that serve alcohol, and in other places.351 The airport stated that, not- withstanding the new legislation, its legal position was that âthe airport continues to fall under the public gathering exception found in the Georgia Code, Section 16-11-127. The airport is a publicly owned and operated building, and it is owned by the City of Atlanta. Therefore, firearms are prohibited on airport property.â352 The airport warned that any- one arriving on MARTA âshould be aware that once you exit the MARTA lobby and enter the terminal, you are on airport property and firearms are prohib- ited. Additionally, firearms are prohibited in the res- taurant located in the public area of the airport.â353 The airport warned that violators would be charged with a misdemeanor offense.354 In Georgiacarry.Org, Inc. v. City of Atlanta,355 the plaintiffs challenged the airportâs policy. The plain- tiffs argued that a Georgia law that âpermits any per- son who possesses a valid Georgia firearms license (âGFLâ) to carry a firearm in the non-sterile areas of the Airportâ¦overrides the Cityâs longstanding policy prohibiting visitors to the Airport from carrying fire- arms.â356 The court did not address the constitutional issue because the court held that the Georgia statute that authorized âGFL holders to carry firearms âin public transportationââ¦does not mention airports, nor does it define âpublic transportation.ââ357 More- over, there was no evidence that the legislature meant for the term âpublic transportationâ to include air- ports.358 Thus, the court dismissed the complaint. As for other states, the Port Authority of New York and New Jersey Airport Rules and Regulations state that, except for authorized personnel identified in the rules, â[n]o person shall carry any firearms, explosives, munitions, or pyrotechnics into the SIDA [Security Identification Display Area] or AOA 350 General Manager Releases Statement Declaring Air- port a Gun-Free Zone, hArtsfieldâJACkson AtlAntA intâl Airport (July 1, 2008), http://www.atlanta-airport.com/ Airport/NewsRoom/Press_Release_Article.aspx?id=572. 351 Id. 352 Id. 353 Id. 354 Id. 355 Id., but see O.C.G.A. Â§ 16-11-130.2(a) (2015). 356 Id. at 1282. 357 Id. at 1284 (citing gA. Code Ann. Â§ 16-11-127(e)). 358 Id. at 1285. 359 port Auth. of n.y. & n.J. Airport rules & regulA- tions 4 (Aug. 4, 2009), available at http://www.panynj.gov/ airports/pdf/rules_regs_revision_8_04_09.pdf. 360 Id. at III. 361 WAyne Cnty. Airport Auth. Airport ordinAnCe 53 (effective Mar. 12, 2013), available at http://www.metro airport.com/Portals/0/PDF/WCAA_Airport_Ordinance_ Mar2013.pdf. 362 Id. Â§ 11.3(iv) (citing 49 C.F.R. Â§ 1542.101(a)(1)). 363 metro. WAsh. Airports Auth. regulAtions Â§ 8.4(1) (a) (July 2014), available at http://www.mwaa.com/file/ PDFregs.PDF. 364 Id. 365 Id. Individuals who are authorized to carry weapons within the sterile area of an airport and law enforcement offi- cers are exempt from the preceding regulation. Id. Â§ 8.4(2). 366 Id. Â§ 8.4(1)(b). 367 Response of Columbia Metropolitan Airport, S.C. (cit- ing Â§ 7-70 of its rules and regulations).
35 F. State Laws Prohibiting Licensed Individuals from Carrying a Concealed Firearm in the Nonsterile Area of an Airport Several statutes provide that a license to carry a concealed handgun does not authorize the licensed holder to carry a handgun into an airport except for shipment as further authorized by law.373 In response to the survey, 17 airports reported that under the laws of their state, a licensee may carry a concealed firearm in the nonsterile area of an airport or on air- port property.374 Eight airports stated that concealed carry firearms could not be carried in the nonsterile area of an airport or on airport property.375 A review Airport in North Dakota,368 Portland International Airport in Oregon,369 LAX,370 and SeattleâTacoma International Airport.371 Thus, based on the statutes located for the digest, airport responses to the survey, and airport rules and regulations or policies, discussed respec- tively in Sections VI.C, VI.D, and VI.E, it appears that 11 states and at least 1 airport in 12 more states ban firearms in airport terminals: Alaska, Arkansas, California, Florida, Iowa, Maine (Augusta State Airport), Maryland, Massachusetts, Michigan (WCAAâDetroit Metropolitan Airport), Mississippi, Nebraska (Lincoln Airport Authority), the Port Authority of New York and New Jersey (five air- ports in the New YorkâNew Jersey area), North Carolina (Charlotte), North Dakota (Bismarck and Grand Forks), Ohio, Oregon (Portland), Pennsylvania (Allegheny County (Pittsburgh) and Philadelphia), South Carolina (Columbia), Tennessee (Blue Grass), Virginia, and Washington (SeattleâTacoma).372 368 Grand Forks International Airport, N.D., Rules and Regulations Â§ 4.11 (Aug. 1, 1995), available at http:// gfkairport.com/wp-content/uploads/pdf/rules_regs.pdf (stating in part that no person may bring any firearms âonto the airportâ except as permitted in the circum- stances described in the section). 369 portlAnd intâl Airport rules 33 (2015), available at https://www.portofportland.com/pdfpop/PDX_Rules.pdf, providing that [n]o persons, except authorized law enforcement offi- cers or members of the armed forces of the United States on official duty, shall possess any firearms or explosives within a Restricted Area without written permission of the ASC, unless under escort by a Port Police officer. This does not apply to persons lawfully transporting or carrying fire- arms or deadly weapons in the General Aviation Area. 370 LAX l.A. World Airports, rules & regulAtions Â§Â§ 2-1 (Mar. 2014), available at http://www.lawa.org/uploadedFiles/ AirOps/pdf/rules/05_Section_02_General_201112.pdf (stat- ing that â[n]o person, shall carry any firearms or explosives at the Airport without permissionâ and that â[a]ll persons other than those in the excepted classes shall, while at the Airport, surrender all such objects in their possession to the Airport Police Divisionâ). Peace officers, post office and customs employees, or members of the armed forces of the United States on official dutyâ are exempt from the regulations. Id. 371 seAttle-tAComA intâl Airport, sChedule of rules & regulAtions No. 5, at 2â3 (Feb. 2015), available at https:// www.portseattle.org/Business/Documents/Rulereg.pdf (stating that â[n]o person may carry firearms on or about the Airport except as allowed by federal and state lawâ). 372 Two more states that possibly may be included as states where firearms are or could be banned in airport terminals under state law are Illinois and New York. In Illinois, 720 ill. Comp. stAt. Ann. 5/24-1(a)(10) (LexisNexis 2015) provides that a person is committing the offense of unlawful use of weapons when the person knowingly, with some exceptions not relevant to the digest, â[c]arries or pos- sesses on or about his person, upon any public street, alley, or other public lands within the corporate limits of a city, village or incorporated townâ¦any pistol, revolver, stun gun or taser or other firearmâ¦.â Another subsection of the stat- ute prohibits a person from carrying a firearm âwhile in a building occupied by a unit of governmentâ¦.â 720 ill. Comp. stAt. Ann. 5/24-1(a)(13) (LexisNexis 2015). On the other hand, licensees possibly are excluded from the above prohibi- tions. See 430 ill. Comp. stAt. Ann. 66/10(c)(1) (LexisNexis 2015) (authorizing the issuance of a license to carry a loaded or unloaded concealed firearm, fully concealed or partially concealed). In New York, a person commits the crime of criminal possession of a weapon in the second degree when the person âpossesses any loaded firearmâ except in the personâs home or place of business. N.Y. penAl lAW Â§ 265.03(3) (Consol. 2015). Moreover, N.Y. penAl lAW Â§ 400(2) (Consul. 2015), applicable to the issuance of licenses to carry firearms, to the extent relevant to the digest, does not appear to authorize unrestricted, open carry of firearms such as to permit a licensee to carry a firearm in an airport. 373 Ark. Code Ann. Â§ 5-73-306(15) (2015) (âNo license to carry a concealed handgun issued pursuant to this sub- chapter authorizes any person to carry a concealed hand- gunâ¦[i]nside the passenger terminal of any airportâ except when a legal firearm âis encasedâ for lawful shipment.) 374 Responses of Albuquerque International Sunport Air- port, N.M.; AustinâBergstrom International Airport, Tex.; Bismarck Municipal Airport, N.D.; Blue Grass Airport, Lexington, Ky. (citing ky. rev. stAt. Ann. Â§ 183.8811); Casper/ Natrona County International Airport, Wyo.; Clinton National/Adams Field Airport, Little Rock, Ark. (citing Ark. Const. art. 2, Â§ 5, Ark. Code Ann. Â§ 5-73-119(e)); Dallas Fort Worth International Airport, Tex. (stating with a permit); Detroit Metropolitan Wayne County Airport, Mich.; George Bush Intercontinental/Houston Airport, Tex.; Huntsville InternationalâCarl T. Jones Field, Ala.; General Mitchell International Airport, Milwaukee, Wisc. (citing Wis. stAt. Â§Â§ 175.60 (concealed carry), 941.23(2)(e) (permit)); Gerald R. Ford International Airport, Grand Rapids, Mich.; Louisville InternationalâStandiford Field, Ky.; Memphis International Airport, Tenn. (citing tenn. Code Ann. Â§ 39-17-1359); Spokane International Airport, Wash. (citing WAsh. rev. Code Ann. Â§ 9.41.300(1)(e)); Theodore Francis Green State AirportâRhode Island Airport Corp. (citing R.I. gen. lAWs Â§ 11-47-11 (license or permit to carry concealed pistol or revolver)); Tucson International AirportâTucson Airport Authority, Ariz. (citing Ariz. rev. stAt. Â§ 13-3102). 375 Responses of Bangor International Airport, Me.; Columbia Metropolitan Airport, S.C.; Eppley Airfield Air- port (Omaha), Neb. (citing neB. rev. stAt. Ann. Â§ 69-2441); Grand Forks International Airport, N.D.; LaGuardia Air- port, N.Y.; Lincoln AirportâLincoln Airport Authority, Neb.; Nashville International Airport, Tenn.; and Joe Foss Field, Sioux Falls, S.D.