What is the current state of the law in the context of strict scrutiny?

Chovan , 735 F.3d at 1138 (internal quotation marks omitted). For strict scrutiny to apply, the law must (1) implicate the core Second Amendment right of defense of home and hearth, and (2) severely burden that right. Pena v. Lindley , 898 F.3d 969, 977 (9th Cir. 2018). If the law "does not implicate the core Second Amendment right or does not place a substantial burden on that right," the court applies intermediate scrutiny. See Fyock , 779 F.3d at 998-99. There has been "near unanimity in the post- Heller case law that, when considering regulations that fall within the scope of the Second Amendment, intermediate scrutiny is appropriate." Silvester , 843 F.3d at 823.