How has the Supreme Court interpreted the meaning of the Second Amendment?
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The Second Amendment does not clearly guarantee individual ownership rights because it is so unclearly written, ambiguous, and confusing.
Show The Second Amendment of the United States Constitution states: “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.”1 The Amendment is poorly written; it’s intent is unclear and language confusing. Perhaps the source of greatest controversy stems from the relationship between the Amendment’s prefatory clause (“A well regulated militia..”) and the operative clause (“the right of the people…”). For decades, political actors, legal scholars and the courts have debated how these clauses relate to one another, if at all, in order to determine the Amendment's true meaning. This debate has led to two competing interpretations: a collective-rights interpretation and an individual-rights interpretation. Because of the Amendment’s ambiguity, it has been malleable to prevailing ideologies in the American political and legal system across several points in history. Both sides of the gun control issue capitalize on the Amendment’s poor and unclear phrasing to support their respective interpretations. The collective-rights interpretation argues that the only rational reason the prefatory clause is included is because it relates to the operative clause. If the framers’ intended to make this Amendment function as a list so that both individuals and militiamen reserve the right to bear arms, surely they would have included an introductory clause to indicate such a function. Therefore, under this interpretation, the Second Amendment is perceived to mean that citizens do not have an individual right to possess guns and that legislative bodies on the local, state, and federal level possess the authority to regulate firearm ownership without impeding on a constitutional right.2 A discussion on the need for gun control and effectiveness of such policies can be found in Appendix A. In contrast, an individual-rights interpretation argues that the Amendment’s prefatory and operative clauses are separable. Relying on the ambiguity in language, proponents of this interpretation question why the founders would include the phrase “right of the people” if they did not intend for it to provide an individual right to bear arms. Therefore, under this interpretation, the Amendment is explained as restricting legislative bodies from prohibiting firearms possession, or at the very least, the Amendment renders prohibitory and restrictive regulation presumptively unconstitutional.2 Despite being so polarizing, there have been relatively few Supreme Court decisions on the matter. Over the last 145 years, there have been five relevant cases on the issue of its meaning. Two of these cases adopted a clear -- and opposing -- interpretation of the Second Amendment’s meaning. In 1939, the U.S. Supreme Court considered the matter in United States v. Miller. The Miller court adopted a collective-rights approach, a precedent that stood for nearly 70 years. The 2008 Supreme Court case, District of Columbia v. Heller, overturned this precedent and adopted an individual-rights approach. Proponents of either interpretation point to three principles to support their approach: (1) the language of the Second Amendment, (2) Supreme Court Precedent, and (3) the historical context of the Amendment. Analyzing these concepts, this paper will argue that a collective-rights interpretation is the accurate explanation of the Amendment’s true meaning. The importance of upholding Supreme Court precedent absent specific legal justification, the inseparability of the operative and prefatory clauses, and insufficient historical evidence to support the notion that the framers intended the Second Amendment to guarantee an individual right makes clear that the Second Amendment does not provide an individual right to keep and bear arms. Overview: Supreme Court Cases and Policy Supreme Court interpretations of the Second Amendment are thus split between two contradicting interpretations with a controversial reversal in 2008. Both approaches rely on Supreme Court precedent to support their respective interpretations of the Second Amendment. The collective-rights interpretation points to the long history of American case law, for example United States v. Cruikshank (1876), that supports this interpretation. In response to recent Supreme Court holdings reversing this precedent, dissenting justices argue the court’s majority misinterpreted the Amendment’s language and historical context. Further, these justices argue that the majority, in misinterpreting and solely relying on history, failed to meet the Supreme Court standard of establishing the right as “fundamental” and therefore erred in incorporating the right. The individual-rights interpretation asserts that court precedent did not foreclose or refute the concept of an individual right to bear arms. Rather, proponents of this interpretation argue precedent asserts the right is not unlimited. Majority and concurring justices in the individual-rights cases rely on the ambiguity in language and history to craft their interpretation. 19th Century Case Law The Supreme Court addressed the issue of the Second Amendment by first considering whether the adoption of the Fourteenth Amendment incorporated the Bill of Rights to state governments and private actors. In 1876, the court in United States v. Cruikshank held that the Fourteenth Amendment did not have this effect and therefore the Second Amendment only applied to the federal government, not the states or private actors.3 In the decades that followed, the court began to apply the Bill of Rights to state governments (i.e. incorporation), but it was not until 134 years after this case that the court came to incorporate the Second Amendment. In 1886, the court in Presser v. Illinois directly addressed the Second Amendment and reaffirmed Cruikshank. Presser concerned a challenge to municipal legislation which limited firearm ownership to ‘the regular organized volunteer militia’ and ‘the troops of the US’.4 The court held that the statute did not violate the defendant’s constitutional rights because, as in Cruikshank, the Second Amendment was not an incorporated right and only applied to the federal government, not municipal or state governments.5 Precedent for Collective-Rights Position In 1934, the federal government enacted the National Firearms Act (NFA). The Act imposed a tax on the making and transfer of firearms defined by the Act and required the registration of all NFA firearms with the Secretary of Treasury.6 NFA firearms included shotguns and rifles having barrels less than 18 inches in length, certain firearms described as “any other weapons,” machine guns, and firearm mufflers and silencers.6 While the NFA was enacted by Congress as an exercise of its taxing power, the Act’s underlying purpose was to curtail, if not prohibit, the transaction and use of NFA firearms which were found to pose a significant crime problem.6 In 1939, the court addressed a challenge to the Act in Miller. Defendants were charged with violating the NFA when they transported unregistered, 12-gauge double barrel shotguns across state lines.7 Defendant’s challenged the NFA as an impermissible infringement on their Second Amendment rights. Under the collective-rights interpretation, the court held the NFA did not violate the defendants’ constitutional rights because the shotguns at issue did not have any reasonable relation to the preservation or efficiency of a well regulated militia.8 Further, the court held that only firearms usable in military service and held for military service purposes were protected by the Second Amendment.9 First Cases for the Individual-Rights Position The collective rights position established in Miller stood as precedent for nearly 70 years until 2008 when it was replaced by the individual's right position in Heller and expanded in 2010 by McDonald. The court addressed a challenge to provisions of the District of Columbia Code concerning firearm ownership and usage in Heller. Provisions of the Code made it illegal to carry an unregistered firearm and prohibited the registration of handguns with minimal exceptions.10 The Code also required owners of lawfully registered firearms to keep them unloaded and disassembled or bound by a trigger lock unless they were located in a place of business or being used for legal recreational activities.10 The plaintiff in this case, a D.C. special police officer, was denied a one-year license for a handgun and sued the District of Columbia arguing, among other things, that the provisions of the Code violated his Second Amendment right to keep a functional firearm in his home without license.11 In a 5-4 decision, the court reversed precedent and adopted an individual-rights interpretation, holding for the Plaintiff. The court reasoned that the Second Amendment protects an individual right to possess a firearm unconnected with service in a militia, and to use that arm for traditionally lawful purposes, such as self-defense within the home.12 Though Heller was significant in that it granted individuals the right to own operative handguns in their homes in the District of Columbia, it was the 2010 case McDonald v. Chicago that extended this right to state and local governments. Similar to Heller, three plaintiff’s brought suit against the city of Chicago, arguing that a city code requirement to register handguns was an impermissible infringement of plaintiff’s Second Amendment rights.13 In holding for the Plaintiffs, the court extended Heller to apply to state and local governments. The court’s majority reasoned that incorporating the Second Amendment was appropriate because the right to bear arms is deeply rooted in US history and tradition.14 Further, the majority argued Second Amendment rights are fundamental to the notion of “liberty” in the 14th Amendment.15 Individual-Rights Interpretation: SCOTUS Majority Opinions and Reasoning The Supreme Court adopted the Individual-Rights interpretation of the Second Amendment in 2008, only after marginalizing and trivializing the first half of the Amendment. That is not at all an acceptable thing to do in constitutional interpretation -- to disregard half of what the framers were trying to say. Under the individual-right theory, the prefatory and operative clauses are considered distinct and separate. The prefatory clause is not viewed as limiting the right to bear arms to the military and formalized-militia. This position interprets historical evidence, such as constitutional-founding era common law doctrine and social norms, as implying an individual right to bear arms. Further, proponents of this interpretation reject that precedent implies a collective-right and rather argue that these cases place limits on individual-rights. Scalia Majority: District of Columbia v. Heller In a 5-4 decision, Justice Scalia-joined by Justices Roberts, Thomas, Kennedy, and Alito-delivered the majority opinion. The majority first looked to the language of the Amendment and determined the Amendment’s prefatory clause does not limit the operative clause. The majority identified two key terms in the operative clause: (1) “right of the people” and, (2) “keep and bear arms.” The phrase “right of the people” appears in the First and Fourth Amendment and similar terminology appears in the Ninth Amendment. The majority asserted that all three instances unambiguously refer to individual rights, not collective.16 They rationalized that when the framers meant to indicate a collective right, they used “the states” rather than “the people.”17 The majority identifies “arms” as applying to weapons not specifically designed for military use.18 “Keep arms” is defined in this opinion as simply a common way of referring to possessing arms, for militiamen and everyone else.19 Although “bear arms” implies carrying of a weapon for the purpose of offensive or defensive action, the majority argues this in no way connotes participation in a structured military organization.20 The majority, after defining these terms, asserts that the operative textual elements together guarantee an individual right to keep and bear arms in cases of confrontation.21 The majority then moved to the prefatory clause and defined “well-regulated militia.” They determined this phrase should not be confined to those serving in the formalized militia and the military. They argue that this is because congress is given the power to provide for calling forth the militia and the power not to create, but to organize the militia. Therefore, one of the intentions of the Amendment -- to give citizens the means to protect themselves against government corruption -- would be defeated if “formalized militia” was interpreted as only applying to the National Guard.22 Further, the phrase “well regulated” justifies an individual rights interpretation because in order for a militia to be “well regulated,” people should have experience with arms through private ownership.23 The court’s majority then looked to the historical context surrounding the Amendment. The majority argues the Framers were aware that many American’s relied on private firearm ownership for hunting and self-defense and thus intended to create an individual right to bear arms through the Second Amendment.24 This argument relies on the “Castle Doctrine.” Similar to modern “Stand Your Ground Doctrine,” “Castle Doctrine '' supported the right to self-defense during home invasion at the time of the Constitution’s ratification.25 Lastly, the court differentiated the issue at hand from precedent. The majority construed Presser as confirming that state governments are not free to infringe on the right of people to bear arms. The majority focused on the portion of Presser that discusses the implications of the Fourteenth Amendment and asserts Presser says nothing about the meaning or scope of the Second Amendment.26 Further, the majority rejects that Miller established a collective-rights presumption. At most, Miller held that short-barreled shotguns are not an “arm” within the meaning of the Amendment.27 Had the Miller court meant to adopt a collective-rights interpretation, the court would not have analyzed the logistics of the firearm, but simply would have ruled against the defendant as he was not a member of the formalized militia.28 Alito Majority: McDonald v. Chicago Justice Alito, joined by Justices Roberts and Kennedy and in part by Justices Scalia and Thomas, delivered the majority opinion. McDonald expanded Heller to apply to state and local governments. The majority focused on the notion of liberty in the Fourteenth Amendment and the country’s “history and traditions” to justify the incorporation of an individual right to bear arms.  The Fourteenth Amendment states in part that “No State shall make or enforce any law which shall abridge the privileges or immunities without due process of law.”29 The Supreme Court has interpreted the Due Process clause to “selectively incorporate various rights;” incorporation of these rights makes them enforceable against the states, not just the federal government.30 The majority held that precedent states the appropriate test to apply a Bill of Rights protection--the Second Amendment in this case-- is to assess whether “a particular Bill of Rights guarantee is fundamental to our scheme of ordered liberty… and deeply rooted in the country’s history and tradition.”31 The majority draws on Heller for much of the support behind their reasoning, specifically Heller’s discussion of historical context. The majority determined that “self-defense” is an implicit and fundamental component of the Second Amendment. In Alito’s words, “Self-defense is a basic right, recognized by many legal systems from ancient times to the present day...”32 This basic right applies to handguns because they are “‘the most preferred firearm in the nation to ‘keep’ and use for protection of one’s home and family,’” and “Heller makes it clear that this right is ‘deeply rooted in this Nation’s history and tradition...’”33 The majority construes Heller’s exploration of the right’s origins in English common law (Castle Doctrine) and the assertion that the Framers were aware that many American’s relied on private firearm ownership for hunting and self-defense as “powerful evidence” of the right being fundamental.34 The majority also refers to Post-Civil War politics and legislation to support their holding. The majority states the Fourteenth Amendment emerged, in part, as a response to Southern States engaging in systematic efforts to disarm and injure African Americans. They point to congressional debates from the 39th Congress, when the Fourteenth Amendment, that referred to the right to keep and bear arms. Through this review, the majority argues that while § 1 of the Fourteenth Amendment does contain an antidiscrimination rule, i.e., the Equal Protection Clause, it cannot be said this section does no more than prohibit discrimination.35 Rather, the historical context of the Fourteenth Amendment supports the notion that the right to keep and bear arms is a fundamental right that deserves the protections the Fourteenth Amendment offers.36 Collective Right Interpretation: SCOTUS Dissenting Opinions and Reasoning Judges who adopt a collective rights interpretation of the Second Amendment take into consideration the whole Amendment as written, reasonably assuming a connection between its two clauses, which they believe should not be denied, thus interpreting the Amendment to say that individuals have a right to be part of a local militia and own a gun for that purpose, and thus otherwise gun ownership can be regulated by local, state and the federal government. A collective-right interpretation considers the operative clause as dependent on the prefatory clause of the Amendment and thus an individual ownership right does not exist outside the context of maintaining a well-regulated militia. The collective-right opinion does not find any compelling historical evidence that the framers intended the Amendment to provide an individual ownership right alone. Further, proponents of this opinion interpret Miller as adopting a clear collective-rights precedent. Stevens’ Dissent: District of Columbia v. Heller Justice Stevens, joined by Justices Breyer, Ginsburg, and Souter, offered a dissenting opinion in Heller. Stevens argued the question of the case was not whether the Second Amendment protects a “collective” or “individual” right, but rather the scope of that right.37 Stevens determined the Second Amendment (1) protects the individual right to bear arms only in the context of military service and (2) does not limit the government's authority to regulate civilian use or possession of firearms.38 Stevens’ first looked at the language of the Amendment. He argues the terms in the prefatory clause are comparable to provisions in several state declarations of rights and those provisions highlight the importance of members of the founding generation attached to the maintenance of state militias. Stevens goes on to compare the Second Amendment’s omission of any statement of purpose related to the right to use arms for hunting or self-defense to certain state declarations that expressly protected such citizen usage at the time of ratification.39 This contrast, Stevens argues, confirms Framers’ focus was to craft a constitutional guarantee to keep and bear arms in relation to military use, which Framers viewed in the context of state militia service.40 Through this analysis, Stevens concludes the preamble of the Second Amendment both sets forth the object of the Amendment and informs the meaning of the remainder of the text. In his words, the text of the prefatory clause should not be treated as “ mere ‘surplusage’ for, ‘it cannot be presumed that any clause in the constitution is intended to be without effect.’”41 Turning to the operative clause, Stevens rejects the majority’s definition of “the people” as including all individuals, and rather determines the phrase refers back to the object announced in the Amendment’s preamble-- members of an organized militia.42 He contends the unmodified use of “bear arms” in the 2nd amendment refers most naturally to a military purpose, as evidenced by dozens of contemporary texts. Had the framers intended to expand the meaning of this phrase to encompass civilian possession and use, they would have done so by adding a phrase such as “for the defense of themselves.”43 Likewise, the unmodified use of “keep arms” implies a military purpose. Stevens points to a number of state militia laws in effect at the time of the Amendement’s drafting which used the term “keep” to describe the requirement that militia members store their arms at their homes to be ready for service whenever necessary.44 Stevens’ next moves to a historical analysis regarding the framers' intentions and the meaning of the Second Amendment. He argues a review of the drafting history of the Amendment reveals that Framers rejected proposals that broadened the Amendment to cover individual usage and subverted Congress’s power to regulate. Stevens writes that Madison’s decision to model the Amendment’s first draft on the distinctly military Virginia proposal is telling in that it is clear he considered and rejected formulations that would have protected civilian use.45 When this first draft was debated and revised, it is reasonable to assume participants in the drafting process were aware of formulations that protected civilian use and possession and the choice to craft the Amendment as they did represents the rejection of those formulations.46 Stevens characterizes the majority’s historical evidence and review of such evidence as strained, unpersuasive, and ultimately a feeble attempt to distinguish Miller.47 Stevens’ then looked to Supreme Court precedent to justify these conclusions. He writes, “the view of the Amendment taken in Miller- that it protects the right to keep and bear arms for certain military purposes, but that it does not curtail the Legislature’s power to regulate- is the most natural reading of the Amendment’s text and the interpretation most faithful to history of its adoption.”48 The dissent argues there is no compelling justification for this long standing precedent to be abandoned, as no new evidence since 1980 has emerged supporting the view that the Amendment was intended to limit the power of Congress to regulate civilian use of arms.49 Breyer’s Dissent: District of Columbia v. Heller Justice Breyer’s dissent, joined by Justices Ginsberg, Souter, and Stevens, argues that even if the Amendment protects an individual’s right to self defense, that assumption should be the beginning, not the end, of the constitutional inquiry. He proposes a “balancing test” that analyzes the “practicalities” to determine which gun control laws are consistent with the Amendment, even if it is interpreted as protected a wholly separate interest in individual self-defense.50 Elaborating, Breyer proposes such a test should take into account the extensive evidence of gun crime and violence in urban areas.51 Under such a test, Breyer determines the handgun ban at issue would be constitutionally permissible.52 Stevens’ Dissent: McDonald v. Chicago Justice Stevens’ McDonald dissent supports the notion of protecting rights through the 14th Amendment, but argued that the majority erred in their approach. Stevens argued that, when confronted with an issue of whether to incorporate a right, the Court should question whether the right violates “values implicit in the concept of ordered liberty.”53 From there, the question in this case then becomes, “whether the interest in keeping in the home a firearm of one’s choosing is one that is ‘comprised within the term liberty’ in the Fourteenth Amendment.”54 Justice Stevens asserts these questions cannot be answered through the majority’s rigid historical analysis. He also points to a long history of local fieram regulations and argues they show how democratic processes can tailor gun laws to local conditions without undermining liberty. He writes, “Framers did not write the Second Amendment in order to protect a private right of armed self defense,” and further, “by its terms, the Second Amendment does not apply to the States; read properly, it does not even apply to individuals outside of the militia context.”55 Breyer’s Dissent: McDonald v. Chicago Justice Breyer’s dissenting opinion, joined by Justices Ginsburg and Sotomayor, disagreed with the majority's determination that the right to possess a handgun is a fundamental right deserving of incorporation. Breyer’s dissent determines the Framers did not write the Second Amendment in order to protect a private right of armed self defense.56 He argues neither Heller nor history implies that the right is, or was, “fundamental.”57 Breyer criticizes the majority’s reliance on Heller considering the numerous scholars and historians that have criticized the holding and argued against its’ extension because of its’ uncertain historical foundations.58 Echoing Stevens’ dissent, Breyer criticizes the majority’s near exclusive reliance on its reading of history to justify its conclusion. He goes on to write that “nothing in 18th, 19th, 20th, or 21st century history shows a consensus that the right to private armed self-defense…. is deeply rooted in this nation’s history or is otherwise fundamental.”59 Breyer states incorporating a right solely on this basis is both wrong and dangerous, as history is often unclear about the answers. Breyer contends firearm regulation is best left to states, in part because the incorporation of the Second Amendment infringes on a long tradition of the exercise of local authority to regulate firearms.60 Conclusion In conclusion, despite confusing wording and sentence structure, most likely the Second Amendment does not support an individual right to keep and bear arms, because supporting such an interpretation would be to ignore the prefatory clause of the Amendment and the relationship this clause shares with the operative. Thus, historical context, Supreme Court precedent, and the language of both clauses taken together (since there is no clear indication not to) probably all indicates that the Amendment does support a collective right to bear arms. Appendix A A collective rights interpretation supports gun control legislation on local and state levels. It is prudent to allow state and local governments to regulate gun control, as the effectiveness of certain policies are oftentimes contingent on geography and social climate. Though individual rights proponents concede the right is not unlimited (e.g., concealed weapons prohibitions, prohibitions on possession by felons and mentally ill, laws forbidding carrying of firearms in sensitive places), many proponents do not support gun control measures that prove most effective in reducing gun related deaths. Influence of powerful lobbyists groups, such as the National Rifle Association (NRA), and individual-rights holdings has made the fight for gun control difficult. Gun rights lobbyist groups have outspent gun control groups over the past decade.61 The NRA, advocates of the individual right interpretation, strongly opposes universal background check legislation, and nearly every other gun control measure, criticizing these laws as overbroad and ineffective.62 It is unclear which gun control policies will be conducive with the court’s current interpretation of the Second Amendment as the Supreme Court has yet to address the issue since McDonald. It is clear that there is a compelling need for gun control policy in the US and that many policies are effective in their goals. Why Gun Control Policy is Necessary According to 2019 data from the CDC, there were 39,707 firearm-related deaths in the US- including suicides, homicides, and accidents.63 Firearm related injuries are among the five leading causes of death for people aged 1-64 in the US.63 Firearm-related deaths disproportionately affect males, youth, and minorities: males account for 86% of all firearm deaths, firearm homicide rates are highest among teens and young adults, and among black, hispanic, and American Indian/Alaskan Native populations.63 As of 2019, the U.S. has the 32nd-highest rate of deaths from gun violence in the world.64 This was nearly more than eight times that in Canada, and nearly 100 times that in the United Kingdom.64 In Canada, it is illegal for anyone, except (for the most part) the police and military, to own automatic weapons and sawed-off shotguns. In the UK, private possession of handguns is almost completely banned. With casualties due to armed conflict factored out, the US gun violence rate is higher than nearly every country in sub-saharan Africa and the Middle East.64 Further, while it is difficult to know exactly how many civilians own guns around the world, by every estimate US civilians own far more firearms than any other country.61 A 2018 survey estimated that in the US, there were 120.5 firearms per 100 residents.61 For perspective, Yemen -- second in this survey -- was estimated to have 52.8 firearms per 100 residents.61 Effectiveness of Gun Control Policy Two 2019 studies assessing FBI and CDC data sets pertaining to gun violence found state laws requiring universal background checks for all gun sales resulted in homicide rates fifteen percent lower than states without such laws.65 As of this study, the homicide rate in the thirteen states that have universal background checks was 3.3 per 100,000 while the thirty seven states that do not have universal background checks experienced a homicide rate of 5.2 per 100,000.65 The study further concluded that certain laws appear to be more effective depending on location. For instance, universal background checks were found to be more effective in large cities, while laws prohibitions on the sale of firearms to persons convicted of violent misdemeanours proved more effective in suburban and rural areas.65 Further, permit requirements were found to be robustly effective regardless of location.65 Researchers feel these results suggest that applying a cluster of different types of state laws is necessary because not every law works the same for each population.65 Gun control policy is effective in lowering rates of violent crimes. States and local governments are best equipped to promulgate these policies as their effectiveness is area specific. In restricting, if not prohibiting, state and local governments ability to promulgate gun control policy, the individual-rights interpretation poses a serious risk to the American public. Notes 1 U.S. Const. amend. II. 2 “Second Amendment.” Legal Information Institute. Legal Information Institute. Accessed August 10, 2021. https://www.law.cornell.edu/wex/second_amendment. 3 United States v. Cruikshank, 92 U.S. 542, 569 (1876) 4 Presser v. Illinois, 116 U.S. 252, 269 (1886) 5 See id. 6 “Bureau of Alcohol, Tobacco, Firearms and Explosives.” National Firearms Act | Bureau of Alcohol, Tobacco, Firearms and Explosives. Accessed August 10, 2021. https://www.atf.gov/rules-and-regulations/national-firearms-act. 7 United States v. Miller, 307 U.S. 174, 183 (1939) 8 See id. at 178. 9 See id. 10 “District of Columbia v. Heller.” Legal Information Institute. Legal Information Institute, June 26, 2008. https://www.law.cornell.edu/supct/html/07-290.ZS.html. 11 District of Columbia v. Heller, 554 U.S. 570, 723 (2008) 12 See id. 13 McDonald v. City of Chicago, 561 U.S. 742, 941 (2010) 14 Id. at 768. 15 See id. at 791. 16 Heller, 544 U.S. at 579-581 17 Id. at 579 18 Id. at 581-582 19 See id. at 582-583 20 See id. at 584-589 21 Id. at 592 22. See id. at 595-598. 23. Id. 24. Id. 25. See id. at 616. 26. Id. at 621. 27. Id. at 622-623 28. See id. 29 U.S. Const. amend. XIV 30 Veronica Rose, Chief Analyst. “Summary of Recent McDonald v. Chicago Gun Case .” Summary of the recent Mcdonald v. Chicago gun case. Accessed August 10, 2021.
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