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Second Amendment Cases Between Miller and Heller

OwenM

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The two (rather contradictory) main Supreme Court rulings on the amendment in the last century are US v Miller in 1939 ("In the absence of any evidence tending to show that possession or use of a ‘shotgun having a barrel of less than eighteen inches in length’ at this time has some reasonable relationship to the preservation or efficiency of a well regulated militia, we cannot say that the Second Amendment guarantees the right to keep and bear such an instrument.") and DC v Heller in 2008 ("There seems to us no doubt, on the basis of both text and history, that the Second Amendment conferred an individual right to keep and bear arms.")
Is there any plausible way another such case could have come up in between? And how might rulings have differed at different times?
 
I wouldn't call them contradictory results, honestly-Heller just says "there is a right and it's an individual right" and Miller says "there is a limit to this right", just as there is a limit to other positive rights (e.g. content-neutral and uniformly applied reasonable time/place/manner restrictions on speech); in this case the problem is that sawed-off shotguns were generally concealed weapons used in organized crime. The main contradiction is focusing on the milita part versus the individual rights part. Also, you're forgetting one very important case which is McDonald v. City of Chicago(incorporating the second amendment against the states).

In terms of how other second amendment cases could have come up-I could see a challenge to the Mulford Act happen maybe. Another option would be a minority self-defense group, which could try to contest what constitutes a "militia." It would be interesting for a case like this to come up before the Rehnquist Court and the rise of its specific brand of textualism/formalism. I wonder what you can have happen if you get a case that intersects with both the Second Amendment and other areas of constitutional law (which kind of happens with United States v. Lopez; in that case a gun-control act was overturned on the grounds that it exceeded congressional power under the Commerce Clause). Could you have a situation where someone tries to litigate a concealed-carry or other state-level permit issued in State A not being recognized in State B on both a second-amendment theory(denial of right to keep and bear arms) and on a Full Faith and Credit theory, and maybe chuck in a Dormant Commerce Clause theory? And does it get dicier if the state in question bans imports of guns from some, but not all states?
 
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