Supreme Court Denies Review in Schoenthal v. Raoul

On April 6, 2026, the United States Supreme Court denied certiorari in Schoenthal v. Raoul, ending a challenge to Illinois' prohibition on carrying concealed firearms aboard public transportation. The denial leaves in place the Seventh Circuit's September 2025 ruling upholding 430 ILCS 66/65(a)(8), the provision of the Firearm Concealed Carry Act that bars licensed carriers from transit facilities, subject to transportation and parking exceptions ^[2].

The Case

Four Illinois concealed carry license holders filed suit in federal district court arguing that the transit ban violated the Second Amendment under New York State Rifle & Pistol Association v. Bruen. The plaintiffs argued that the lack of firearm regulation for public transportation at the Founding made the ban unconstitutional ^[1].

The district court ruled in favor of the plaintiffs, holding 430 ILCS 66/65(a)(8) unconstitutional as applied to those plaintiffs. On appeal, the Seventh Circuit reversed in September 2025, upholding the transit ban under Bruen's "sensitive places" framework. The appellate panel held that the transit prohibition fit within a historical tradition of regulating firearms in "sensitive places" and that publicly funded transit systems qualified under Bruen's framework ^[1].

The Supreme Court Denial

The plaintiffs filed a petition for certiorari with the Supreme Court, docketed as case 25-541. On April 6, 2026, the Court denied the petition without comment or recorded dissent. The denial leaves the Seventh Circuit's judgment in place ^[2].

What This Means for Illinois CCL Holders

Illinois law continues to prohibit carrying concealed firearms on CTA, Metra, Pace, and other transportation paid for in whole or in part with public funds, subject to transportation and parking exceptions. A licensee who knowingly carries a firearm into a prohibited transit facility in violation of the Act commits a Class B misdemeanor for a first violation or a Class A misdemeanor for a second or subsequent violation. The Illinois State Police may suspend a license for up to 6 months for a second violation and shall permanently revoke a license for 3 or more violations of Section 65.

The public-transit restriction in 430 ILCS 66/65(a)(8) applies to transportation paid for in whole or in part with public funds. Exceptions apply when a person carries a firearm that is broken down, properly stored, or not immediately accessible under 720 ILCS 5/24-1(a)(4)(i) through (iii). Riders should continue to consult 430 ILCS 66/65 for the full list of prohibited locations.

The parking-area exception in 430 ILCS 66/65(b) applies at transit parking areas. A licensee using a park-and-ride lot may store a firearm concealed in a case within a locked vehicle or a locked container out of plain view within the vehicle, even though carrying the firearm onto the bus or train itself is prohibited.