In 1920, the Ohio Supreme Court upheld the conviction of a Mexican for concealed carry of a handgun–while asleep in his own bed. Justice Wanamaker’s scathing dissent criticized the precedents cited by the majority in defense of this absurdity:
"I hold that the laws of the state of Ohio should be so applied and so interpreted as to favor the law-abiding rather than the law-violating people. If this decision shall stand as the law of Ohio, a very large percentage of the good people of Ohio to-day are criminals, because they are daily committing criminal acts by having these weapons in their own homes for their own defense. The only safe course for them to pursue, instead of having the weapon concealed on or about their person, or under their pillow at night, is to hang the revolver on the wall and put below it a large placard with these words inscribed: “The Ohio supreme court having decided that it is a crime to carry a concealed weapon on one’s person in one’s home, even in one’s bed or bunk, this weapon is hung upon the wall that you may see it, and before you commit any burglary or assault, please, Mr. Burglar, hand me my gun.”
State v. Nieto, 101 Ohio St. 409, 430, 130 N.E. 663 (1920).