This story is part of a KXAN series of reports called “Stop Mass Shootings,” providing context and exploring solutions surrounding gun violence in the wake of the deadly Uvalde school shooting. We want our reports to be a resource for Texans, as well as for lawmakers who are convening a month after the events in Uvalde to discuss how the state should move forward. Explore all “Stop Mass Shootings” stories by clicking here.

AUSTIN (KXAN) — “A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.”

Since its ratification into law in 1791, the Second Amendment has helped shaped American culture for more than 230 years. For some, guns are used as a form of recreation for hunting and target shooting. For others, guns can serve as a form of safety, security and protection codified into American law.

“The Second Amendment means I have the right to own and carry weapons,” Steven Lanz, an Austin gun owner, told KXAN ahead of attending a gun safety course.

In the United States, the influence of the Second Amendment is reflected in gun ownership patterns. As of 2018, Americans owned 393 million guns, or 1.2 guns per person, according to data gathered by the independent research project Small Arms Survey. Americans own more guns than the combined amount of guns owned by people in the other top 25 countries globally.

“If there’s any area where the United States is truly exceptional worldwide, it’s gun ownership,” said Aaron Karp, senior consultant to Small Arms Survey. “The United States is a country where there are more guns than there are people. There’s no other country like that.”

In 2020, more than 19,000 homicides in the U.S. involved guns, according to data from the Centers for Disease Control and Prevention. So far this year, Education Week has reported 27 shootings on school campuses, where 83 people have been injured or killed.

In the U.K., there were 30 gun-based homicides committed in the year ending March 31, 2020 — accounting for 4% of all homicides that year, according to data from the U.K. Parliament’s House of Commons Library. There have been no additional school shootings since the 1996 Dunblane massacre in Scotland, when 16 students and one teacher were killed by a gunman.

San Antonio native Elva Mendoza joined Moms Demand Action shortly after the organization’s founding in 2013, in the wake of the Sandy Hook shooting. The group comprises a survivor network of people directly affected by gun violence.

Since then, she and her family relocated to Spain where, despite also having violence and crime, she said the magnitude of mass gun violence doesn’t reach American levels. In 2018, Small Arms Survey recorded 39 violent deaths caused by firearms in Spain; by comparison, there were 12,332 reported in the U.S.

“It’s very frustrating because I know that it can be safer in the U.S., and Americans deserve to feel safe in their churches, in their movie theaters, in their schools and on the street,” she said. “We deserve that and it can happen.”

While some new laws have been introduced at the state and federal level, mass shootings continue to happen in the U.S. on a frequent basis. Despite the U.S. not being the only country to experience mass gun violence, other countries have taken alternative approaches to try and mitigate large-scale violence.

United Kingdom

In 1996, Britain experienced its deadliest school shooting when a shooter armed with four handguns killed a teacher and 16 children in the small town of Dunblane, Scotland. Among those killed was Mick North’s 5-year-old daughter Sophie.

North described the aftermath’s reaction as “one of absolute horror” that rocked not only Scotland, but the UK as a whole.

“Most people were totally surprised that anyone could get ahold of handguns as easily as the perpetrator and wanted change,” he said. “So there was an outpouring of grief, but also a push for something to be done quickly, so that the risk of such an event happening again would be severely reduced.”

Victims’ families and gun control advocates successfully lobbied with British lawmakers to enact the Firearms (Amendment) (No. 2) Act in 1997, a legislative policy that originally banned handguns above a .22 caliber. It was later extended to ban all handguns.

Since then, no school shootings have happened in the United Kingdom. But North said the success of that legislative policy was due, in part, to the fact Britain didn’t have a Second Amendment-esque piece of legislation it had to combat.

“It was quite a drastic shift for Britain — obviously not the same as it would be in the States, because there’s no concept of a right to bear arms,” North said. “But to remove a whole category of weapons, handguns, from legal ownership, was a huge step.”

Rosemary Hunter had been living in Dunblane at the time of the mass shooting. Following the shooting, she became an organizer of the Dunblane Snowdrop Campaign, which successfully lobbied for enhanced gun control.

While she said there’s no clean parallel between gun lobbyists in the U.K. versus the U.S., she said their efforts were met with resistance from legislators in power. It wasn’t until the Labour Party replaced the Conservative Party the following year that any legislative changes were enacted, she said.

“[The Labour Party] had said to us as the campaigners that if they got in, they would put it through as one of their first pieces of legislation. And that’s what they did,” she said. “But that’s not to say we didn’t have a lot of resistance to that amongst the gun lobby.”

Following the Dunblane shooting, Conservative Prime Minister John Major introduced the Firearms (Amendment) Act 1997. The legislation banned high-caliber handguns, a style used by the Dunblane shooter, but permitted .22 rimfire handguns to be “used and kept” in licensed clubs.

A few months after its passage, the Conservative Party lost the 1997 general election, with Labour Party leader Tony Blair coming to power as prime minister. Under his leadership, Blair proposed and helped pass the Firearms (Amendment) (No. 2) Act 1997, which banned ownership of .22 handguns and virtually banned all handguns from private use.

“To remove a whole category of weapons, handguns, from legal ownership, was a huge step.”

Mick North, father of Dunblane, Scotland, mass shooting victim

With a complete ban on handguns in place, Hunter acknowledged it’s been 26 years since a mass school shooting in the U.K. That doesn’t mean the U.K. hasn’t had concerns with gun violence since.

In 2018, there were 30 violent deaths caused by firearms reported in the U.K., per Small Arms Survey.

Hunter said there are still issues with illegally-owned guns or violence stemming from rifles or shotguns, but not to the extent seen elsewhere.

“There is a feeling of safety, and I think there’s a general acceptance that it’s the correct decision that we made as a culture,” she said.

Despite significant reductions in the U.K.’s gun violence in the years since, some policy experts say those same measures wouldn’t likely translate into American legislative changes.

Sanford Levinson, a professor at the University of Texas School of Law, said the U.S. differs significantly from the U.K. due to the U.S.’s “more libertarian culture” when it comes to guns. He cited the 2008 District of Columbia v. Heller Supreme Court ruling, in which the Court ruled the Second Amendment does protect an individual’s right to keep and bear arms in relation to self-protection.

“I think the United States, for better and for worse, is a far more libertarian culture than the U.K., or you could argue than any other country on the face of the earth,” Levinson said.

“The debate now has almost nothing to do with handguns, or [handguns] in your home. It has to do with whether you can carry guns wherever you want,” he continued, adding: “A ban on handguns? No, that is not in the future. I see no circumstances where public opinion would move, really, to support that.”

Canada

Heidi Rathjen was 21 years old when a shooter entered her classroom at École Polytechnique de Montréal in December 1989, murdering 14 women and injuring 14 other men and women. More than 30 years later, she continues advocacy efforts as part of PolyRemembers, a collection of witnesses, survivors and relatives of the mass shooting’s victims who all campaign for gun control policymaking.

While Canadian gun policies differ from the U.S., Rathjen criticized some international perception of Canadian gun legislation, saying it isn’t as tough as countries in Europe, New Zealand and Australia. Initial legislation passed several years after the Polytechnique mass shooting was later rolled back in the early 2000s, frustrating fellow survivors and the victims’ family members.

When Prime Minister Justin Trudeau came to power in 2015, she said there were incremental measures taken, but minimal comprehensive efforts.

However, just days after the Uvalde school shooting, Trudeau put new legislation on the table that, among other things, would impose a national freeze on importing, buying, selling or transferring handguns — essentially capping the number of handguns in circulation in Canada. The legislation would also permit the removal of gun licenses from people who’ve committed domestic violence or criminal harassment, per reporting from CBC News.

“In the long run, the idea is to phase out handguns with every generation, so there won’t be any new orders of handguns and those that have them now can keep them until they pass away, and then they would be out of the system, out of circulation,” Rathjen said.

Following an April 2020 mass shooting in Nova Scotia where a shooter killed 22 people and injured three others, Trudeau announced a ban of more than 1,500 models of assault-style firearms, including M16s, AR-10s, AR-15s and M4 patterns of firearms.

While technically banned, Rathjen said many models remain out there, with an awaited buyback program to begin in the fall.

“It’s taking a long time. New Zealand did it in only six months (in 2019, following the Christchurch mosque shootings),” she said. “But [officials] say it’s going to start in the fall, so that’s good news.”

With this latest legislation some of the most significant taken in Canada’s policy history, Rathjen said it’s a mixture of relief and frustration, given the 30-plus year fight for enhanced gun policies. While Canada doesn’t have one single, primary gun lobby organization like the National Rifle Association in the U.S., she said lobbyists continue to influence Canadian responses to gun regulations.

The Canadian Coalition for Firearms Rights is the only in-house registered lobbyist group, whose policy efforts focus on personal and property defense rights, concealed or open carry rights, mandatory firearms safety trainings and removing “restrictions on the types of weapons used for hunting.”

“[Gun ownership] is not a right in Canada. It’s a privilege that government may decide somebody or some people cannot have guns. You can regulate them.”

Francis Langlois, professor of history, Cégep de Trois-Rivières

“When you think of Canada as a whole — our traditions, our values, public opinion are all in favor of banning these [handguns and assault-style] weapons,” she said. “We’re not for banning hunting rifles and shotguns, but handguns and assault weapons do not belong in the hands of civilians.”

Francis Langlois is a professor of history at Cégep de Trois-Rivières in Quebec, with expertise in American history and firearms policy in both the U.S. and Canada. When comparing U.S. gun policymaking compared to western democracies in Canada, the U.K. and Australia, he said America’s political system has diluted legislative responses following mass shootings.

“It’s quite easier to play defensive. If you want to block any law that could be adopted by the government, it’s easier to play defensive than offensive, to implement the law,” he said. “President Clinton was very, I would say, skilled when he instituted the assault weapon ban because it was quite difficult. President Johnson in 1968 was able to implement, to put in place some gun laws. But you had to put a lot of water into wine to dilute the power of the law and the power of the federal government for firearm gun controls.”

Langlois said much of American gun culture stems from the Second Amendment, a uniquely American liberty. However, Langlois said this idea of gun access as an American right has trickled north into gun policy discussions within Canada.

“Gun lobby-sponsored discourse is percolating here, in the sense that we can hear people saying that having a gun here is a right. It’s not a right in Canada. It’s a privilege that government may decide somebody or some people cannot have guns, you can regulate them,” he said. “But in the use of this discourse, they also use a lot of the idea of guns as a tool for protection, as a synonym for liberty. So it’s quite strong.”

Despite American liberty philosophies echoed in Canada, Langlois said it’s a unique vantage point when mass shootings, like the one in Uvalde, happen in the U.S.

“When there was a shooting, people here will say, ‘You see, we are different. We are more regulated.’ We’re more, I would say, prudent, responsible citizens,'” Langlois said. “But there have been shootings here, too.”