Changes

== Individual or Collective Right? ==

== Individual or Collective Right? ==

One of the first people to advance the notion that the Second Amendment was never for individuals but was instead a "collective right", was [[Warren Burger]], who in 1990 wrote an article in Parade Magazine arguing a limited context based on the needs of only a state, not individuals.<ref>[https://guncite.com/burger.html The Right To Bear Arms], By Warren E. Burger, Chief Justice of the United States (1969-86), Parade Magazine, January 14, 1990, page 4</ref><ref>[https://buckscountyherald.com/stories/no-confusion-in-meaning-of-the-second-amendment,10169 No confusion in meaning of the Second Amendment]</ref>  Burger's rationale was never a part of official Supreme Court opinions nor was it a part of a long and well-researched historical work with deep citations and long quotes.  Rather, the entire article is roughly 900 words and happily takes several facts out of context.<ref>[https://davekopel.org/2A/Mags/crburger.htm Warren Burger and the Second Amendment]</ref>

One of the first people to advance the notion that the Second Amendment was never for individuals but was instead a "collective right", was [[Warren Burger]], who in 1990 wrote an article in Parade Magazine arguing a limited context based on the needs of only a state, not individuals.<ref>[https://guncite.com/burger.html The Right To Bear Arms], By Warren E. Burger, Chief Justice of the United States (1969-86), Parade Magazine, January 14, 1990, page 4</ref><ref>[https://buckscountyherald.com/stories/no-confusion-in-meaning-of-the-second-amendment,10169 No confusion in the meaning of the Second Amendment]</ref>  Burger's rationale was never a part of official Supreme Court opinions nor was it a part of a long and well-researched historical work with deep citations and long quotes.  Rather, the entire article is roughly 900 words and happily takes several facts out of context.<ref>[https://davekopel.org/2A/Mags/crburger.htm Warren Burger and the Second Amendment]</ref>

Afterwards, lower federal courts became much more comfortable interpreting the Second Amendment as protecting merely a collective right of state militias now that they had the weight of a former Chief Justice lending power to such claims.<ref>http://www.davekopel.com/2A/LawRev/35finalpartone.htm</ref> However, the [[U.S Supreme Court]] has always called it an individual right. The 2008 Supreme Court decision of ''[[District of Columbia v. Heller]]'' ruled 5–4 that the Second Amendment protects an individual right. This decision was expanded upon in ''[[McDonald v. Chicago]]'' two years later, which ruled that Second Amendment applies to protect individual rights against state and city laws also.

Afterward, lower federal courts became much more comfortable interpreting the Second Amendment as protecting merely a collective right of state militias now that they had the weight of a former Chief Justice lending power to such claims.<ref>http://www.davekopel.com/2A/LawRev/35finalpartone.htm</ref> However, the [[U.S Supreme Court]] has always called it an individual right. The 2008 Supreme Court decision of ''[[District of Columbia v. Heller]]'' ruled 5–4 that the Second Amendment protects an individual right. This decision was expanded upon in ''[[McDonald v. Chicago]]'' two years later, which ruled that the Second Amendment applies to protect individual rights against state and city laws also.

Many pithy quotes by [[Founding Fathers]] support the Second Amendment right of individuals.<ref>https://www.concealedcarry.com/gun-quotes-from-our-founding-fathers-2nd-amendment/</ref>

Many pithy quotes by [[Founding Fathers]] support the Second Amendment right of individuals.<ref>https://www.concealedcarry.com/gun-quotes-from-our-founding-fathers-2nd-amendment/</ref>

<blockquote>To vindicate these rights, when actually violated or attacked, the subjects of England are entitled, in the first place, to the regular administration and free course of justice in the courts of law; next to the right of petitioning the king and parliament for redress of grievances; and lastly '''to the right of having and using arms for self-preservation and defence.'''</blockquote>

<blockquote>To vindicate these rights, when actually violated or attacked, the subjects of England are entitled, in the first place, to the regular administration and free course of justice in the courts of law; next to the right of petitioning the king and parliament for redress of grievances; and lastly '''to the right of having and using arms for self-preservation and defence.'''</blockquote>

For this reason, in the years of 1774 and 1775 when several incidents happened to give the colonists a fear that the British would take their guns away they were willing to stand up and defend their rights.

For this reason, in the years 1774 and 1775 when several incidents happened to give the colonists a fear that the British would take their guns away they were willing to stand up and defend their rights.

In September 1774, the [[Powder Alarm]] was a response to the removal of gunpowder from a magazine located in Somerville, Massachusetts.<ref>[https://www.massar.org/2014/12/07/building-to-a-revolution-the-powder-alarm-and-popular-mobilization-of-the-new-england-countryside-1774-1775/ The Powder Alarm and Mobilization of the New England Countryside, 1774-1775]</ref>  In October 1774, the king passed an order in arms edict<ref>[https://books.google.com/books?id=8hgUAAAAYAAJ&pg=PA584 Pennsylvania Archives], 1853, full text - "An Act to impower His Majesty to prohibit the Exportation of Saltpetre, & to enforce the Law for impowering His Majesty to prohibit the Exportation of Gunpowder or any sort of Arms & Ammunition"</ref> forbidding the export of arms or ammo to the colonies.  Word of this embargo quickly spread, and shortly after learning of it Patriots in New Hampshire raided the Fort William and Mary, removing all gunpowder and arms before any could be confiscated.<ref>[https://archive.org/details/captureoffortwil00pars The capture of Fort William and Mary], by Charles Lathrop Parsons</ref>  In 1775, [[Patrick Henry]] led a militia force after the [[Gunpowder Incident]] in Williamsburg, Virginia.<ref>[https://www.taraross.com/post/tdih-gunpowder-incident This Day in History: The Gunpowder Incident nearly incites rebellion in Virginia]</ref>

In September 1774, the [[Powder Alarm]] was a response to the removal of gunpowder from a magazine located in Somerville, Massachusetts.<ref>[https://www.massar.org/2014/12/07/building-to-a-revolution-the-powder-alarm-and-popular-mobilization-of-the-new-england-countryside-1774-1775/ The Powder Alarm and Mobilization of the New England Countryside, 1774-1775]</ref>  In October 1774, the king passed an order in arms edict<ref>[https://books.google.com/books?id=8hgUAAAAYAAJ&pg=PA584 Pennsylvania Archives], 1853, full text - "An Act to impower His Majesty to prohibit the Exportation of Saltpetre, & to enforce the Law for impowering His Majesty to prohibit the Exportation of Gunpowder or any sort of Arms & Ammunition"</ref> forbidding the export of arms or ammo to the colonies.  Word of this embargo quickly spread, and shortly after learning of it Patriots in New Hampshire raided the Fort William and Mary, removing all gunpowder and arms before any could be confiscated.<ref>[https://archive.org/details/captureoffortwil00pars The capture of Fort William and Mary], by Charles Lathrop Parsons</ref>  In 1775, [[Patrick Henry]] led a militia force after the [[Gunpowder Incident]] in Williamsburg, Virginia.<ref>[https://www.taraross.com/post/tdih-gunpowder-incident This Day in History: The Gunpowder Incident nearly incites rebellion in Virginia]</ref>

In 1787, to address these weaknesses, the [[Constitutional Convention]] was held with the idea of amending the Articles. When the convention ended with a proposed [[Constitution]], those who debated the ratification of the Constitution divided into two camps; the [[Federalist]]s (who supported ratification of the Constitution) and the [[Anti-Federalists]] (who opposed it).

In 1787, to address these weaknesses, the [[Constitutional Convention]] was held with the idea of amending the Articles. When the convention ended with a proposed [[Constitution]], those who debated the ratification of the Constitution divided into two camps; the [[Federalist]]s (who supported ratification of the Constitution) and the [[Anti-Federalists]] (who opposed it).

Among their objections to the Constitution, anti-Federalists feared a standing army that could eventually endanger [[democracy]] and [[civil liberties]]. Although the anti-Federalists were unsuccessful at blocking ratification of the Constitution, through the Massachusetts Compromise they insured that a [[Bill of Rights]] would be made, which would provide constitutional guarantees against taking away certain rights.

Among their objections to the Constitution, anti-Federalists feared a standing army that could eventually endanger [[democracy]] and [[civil liberties]]. Although the anti-Federalists were unsuccessful at blocking ratification of the Constitution, through the Massachusetts Compromise they ensured that a [[Bill of Rights]] would be made, which would provide constitutional guarantees against taking away certain rights.

One of those rights was the right to bear arms.  This was intended to prevent the Federal Government from taking away the ability of the states to raise an army and defend itself and arguably to prevent them from taking away from individuals the ability to bear arms.

One of those rights was the right to bear arms.  This was intended to prevent the Federal Government from taking away the ability of the states to raise an army and defend itself and arguably to prevent them from taking away from individuals the ability to bear arms.

[[Supreme Court]] opinions have all been consistent with the individual rights interpretation of the Second Amendment, but the lower court opinions are mixed.  

[[Supreme Court]] opinions have all been consistent with the individual rights interpretation of the Second Amendment, but the lower court opinions are mixed.  

As of 2007, people argue about the meaning of the Second Amendment, but there is no definitive answer. The latest ruling is ''Parker v District of Columbia'', in which the DC Circuit court of appeals ruled on March 9, 2007, that the [[Washington, D.C.|DC]] gun ban violated individual rights under the Second Amendment.

As of 2007, people argue about the meaning of the Second Amendment, but there is no definitive answer. The latest ruling is ''Parker v District of Columbia'', in which the U.S. Court of Appeals for the [[D.C. Circuit]] ruled on March 9, 2007, that the [[Washington, D.C.|DC]] gun ban violated individual rights under the Second Amendment.

==Militia clause==

==Militia clause==

The Second Amendment begins with the phrase "''A well regulated militia, being necessary to the security of a free state''".  This phrase has created quite a lot of contention with those who believe this is a triumph for the regulatory state, or that it means only military members can own guns.  As many of the Founding Fathers have explained, the militia is the whole people.  Thomas M. Cooley's ''Principles of Constitutional Law'' explains that this right is an individual right for the whole people and why that is a benefit for themselves and for government:

The Second Amendment begins with the phrase "''A well regulated militia, being necessary to the security of a free state''".  This phrase has created quite a lot of contention with those who believe this is a triumph for the regulatory state, or that it means only military members can own guns.  As many of the Founding Fathers have explained, the militia is the whole people.  Thomas M. Cooley's ''Principles of Constitutional Law'' explains that this right is an individual right for the whole people and why that is a benefit for themselves and for the government:

<blockquote>The Right is General. - It might be supposed from the phraseology of this provision that the right to keep and bear arms was only guaranteed to the militia; but this would be an interpretation not warranted by the intent. The militia, as has been explained elsewhere, consists of those persons who, under the law, are liable to the performance of military duty, and are officered and enrolled for service when called upon.  But the law may make provision for the enrolment of all who are fit to perform military duty, or of a small number only, or it may wholly omit to make any provision at all; and ''if the right were limited to those enrolled, the purpose of the guarantee might be defeated altogether by the action or the neglect to act of the government it was meant to hold in check''. The meaning of the provision undoubtedly is, that the people, from whom the militia must be taken, shall have the right to keep and bear arms; and they need no permission or regulation of law for the purpose. But this enables the government to have a well regulated militia; for to bear arms implies something more than mere keeping; it implies the learning to handle and use them in a way that makes those who keep them ready for their efficient use; in other words, it implies the right to meet for voluntary discipline in arms, observing in so doing the laws of public order.<ref>[https://www.google.com/books/edition/The_General_Principles_of_Constitutional/SkFMAAAAMAAJ?hl=en&gbpv=1&pg=PA271 The General Principles of Constitutional Law in the United States of America], Thomas M. Cooley, 1880</ref></blockquote>

<blockquote>The Right is General. - It might be supposed from the phraseology of this provision that the right to keep and bear arms was only guaranteed to the militia; but this would be an interpretation not warranted by the intent. The militia, as has been explained elsewhere, consists of those persons who, under the law, are liable to the performance of military duty, and are officered and enrolled for service when called upon.  But the law may make provision for the enrolment of all who are fit to perform military duty, or of a small number only, or it may wholly omit to make any provision at all; and ''if the right were limited to those enrolled, the purpose of the guarantee might be defeated altogether by the action or the neglect to act of the government it was meant to hold in check''. The meaning of the provision undoubtedly is, that the people, from whom the militia must be taken, shall have the right to keep and bear arms; and they need no permission or regulation of law for the purpose. But this enables the government to have a well regulated militia; for to bear arms implies something more than mere keeping; it implies the learning to handle and use them in a way that makes those who keep them ready for their efficient use; in other words, it implies the right to meet for voluntary discipline in arms, observing in so doing the laws of public order.<ref>[https://www.google.com/books/edition/The_General_Principles_of_Constitutional/SkFMAAAAMAAJ?hl=en&gbpv=1&pg=PA271 The General Principles of Constitutional Law in the United States of America], Thomas M. Cooley, 1880</ref></blockquote>

Participants in the various debates on firearms, crime, and constitutional law may have noticed that the Second Amendment is often quoted differently by those involved. The two main variations differ in punctuation &mdash; specifically, in the number of commas used to separate those twenty-seven words. But which is the correct one? The answer to this question must be found in official records from the early days of the republic when the Bill of Rights was sent by the First Congress to the states for ratification. Therefore, a look at the progression of this declaratory and restrictive clause from its inception to its final form is in order.

Participants in the various debates on firearms, crime, and constitutional law may have noticed that the Second Amendment is often quoted differently by those involved. The two main variations differ in punctuation &mdash; specifically, in the number of commas used to separate those twenty-seven words. But which is the correct one? The answer to this question must be found in official records from the early days of the republic when the Bill of Rights was sent by the First Congress to the states for ratification. Therefore, a look at the progression of this declaratory and restrictive clause from its inception to its final form is in order.

Before beginning, one must note that common nouns, like "state" and "people," were often capitalized in official and unofficial documents of the era. Also, an obsolete formation of the letter "s" used to indicate the long "s" sound was in common usage. The long 's' is subject to confusion with the lower case  'f', therefore, Congress" is sometimes spelled as "Congrefs," as is the case in the parchment copy of the Bill of Rights displayed by the National Archives. The quotations listed here are accurate. With the exception of the omission of quotations marks, versions of what is now known as the Second Amendment in boldface appear with the exact spelling, capitalization, and punctuation as the cited originals.

Before beginning, one must note that common nouns, like "state" and "people," were often capitalized in official and unofficial documents of the era. Also, an obsolete formation of the letter "s" used to indicate the long "s" sound was in common usage. The long 's' is subject to confusion with the lowercase 'f', therefore, Congress" is sometimes spelled as "Congrefs," as is the case in the parchment copy of the Bill of Rights displayed by the National Archives. The quotations listed here are accurate. With the exception of the omission of quotations marks, versions of what is now known as the Second Amendment in boldface appear with the exact spelling, capitalization, and punctuation as the cited originals.

==Chronological History==

==Chronological History==

{{cquote|...a well regulated militia, being the best security of a free state, the right of the people to keep and bear arms, shall net be infringed.<ref>U.S. Senate Journal, 1st Cong., 1st sess., 4 September 1789.</ref>}}

{{cquote|...a well regulated militia, being the best security of a free state, the right of the people to keep and bear arms, shall net be infringed.<ref>U.S. Senate Journal, 1st Cong., 1st sess., 4 September 1789.</ref>}}

In further debates on September 9, the Senate agreed to strike the words, "the best," and replace them with, "necessary to the." Since the third and fourth articles had been combined, the Senators also agreed to rename the amendment as Article the Fourth. The Senate Journal that day carried the article without the word, "best," but also without the replacements, "necessary to." Note that the extraneous commas have been omitted:

In further debates on September 9, the Senate agreed to strike the words, "the best," and replace them with, "necessary to the." Since the third and fourth articles had been combined, the Senators also agreed to rename the amendment as Article the Fourth. The Senate Journal that day carried the article without the word, "best," but also without the replacement, "necessary to." Note that the extraneous commas have been omitted:

{{cquote|A well regulated militia being the security of a free state, the right of the people to keep and bear arms shall not be infringed.<ref>U.S. Senate Journal, 1st Cong., 1st sess., 9 September 1789.</ref>}}

{{cquote|A well regulated militia being the security of a free state, the right of the people to keep and bear arms shall not be infringed.<ref>U.S. Senate Journal, 1st Cong., 1st sess., 9 September 1789.</ref>}}

{{cquote|Article the Fourth. 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.<ref>Bill of Rights. National Archives and Records Administration. http://www.nara.gov/exhall/charters/billrights/bill.jpg, 22 January 2000.</ref>}}

{{cquote|Article the Fourth. 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.<ref>Bill of Rights. National Archives and Records Administration. http://www.nara.gov/exhall/charters/billrights/bill.jpg, 22 January 2000.</ref>}}

The above version is used almost exclusively today, but aside from the parchment copy, the author was unable to find any other official documents from that era which carry the amendment with the extra commas. In fact, in the appendix of the Senate Journal, Article the Fourth is entered as reading:

The above version is used almost exclusively today, but aside from the parchment copy, the author was unable to find any other official documents from that era that carry the amendment with the extra commas. In fact, in the appendix of the Senate Journal, Article the Fourth is entered as reading:

{{cquote|Art. IV. 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.<ref>U.S. Senate Journal. 1st Cong., 1st sess., Appendix.</ref>}}

{{cquote|Art. IV. 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.<ref>U.S. Senate Journal. 1st Cong., 1st sess., Appendix.</ref>}}

{{cquote|Article the Fourth. 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.<ref>Annals of Congress, 1st Cong., 1st sess., Appendix</ref>}}

{{cquote|Article the Fourth. 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.<ref>Annals of Congress, 1st Cong., 1st sess., Appendix</ref>}}

Further, once two-thirds of both chambers of the Congress agreed to the proposed amendments, the House passed a resolve to request that the President send copies of them to the governors of the eleven states in the Union, and to those of Rhode Island and North Carolina. The Senate concurred on September 26, as recorded in their journal:

Further, once two-thirds of both chambers of Congress agreed to the proposed amendments, the House passed a resolution to request that the President send copies of them to the governors of the eleven states in the Union, and to those of Rhode Island and North Carolina. The Senate concurred on September 26, as recorded in their journal:

{{cquote|Resolved by the Senate and House of Representatives of the United States of America in Congress assembled, That the President of the United States be requested to transmit to the executives of the United States, which have ratified the constitution copies of the amendments proposed by Congress, to be added thereto; and like copies to the executives of the states of Rhode Island and North Carolina.<ref>U.S. Senate Journal. 1st Cong. 1st sess., 26 September 1789.</ref>}}

{{cquote|Resolved by the Senate and House of Representatives of the United States of America in Congress assembled, That the President of the United States be requested to transmit to the executives of the United States, which have ratified the constitution copies of the amendments proposed by Congress, to be added thereto; and like copies to the executives of the states of Rhode Island and North Carolina.<ref>U.S. Senate Journal. 1st Cong. 1st sess., 26 September 1789.</ref>}}

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.<ref>The Federalist on the New Constitution, 1796. The Constitution for the United States, Its Sources and Its Applications. http://www.nidlink.com/~bobhard/f16b1234.jpg, 17 February 2000.</ref>}}

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.<ref>The Federalist on the New Constitution, 1796. The Constitution for the United States, Its Sources and Its Applications. http://www.nidlink.com/~bobhard/f16b1234.jpg, 17 February 2000.</ref>}}

This version is carried throughout the 19th Century, in such legal treatises as Joseph Story's Commentaries on the Constitution of the United States (1833) and Thomas Cooley's Principles of Constitutional Law (1898). It is also transcribed in this manner in the 1845 Statutes at Large, although the term "state" is capitalized in that text. The latter are the official source for acts of Congress.<ref>Commentaries on the Constitution of the United States. The Constitution Society. http://www.constitution.org/js/js_344.htm, 18 February 2000.</ref><ref>Quotes from Constitutional Commentators. Gun Cite. http://www.guncite.com/gc2ndcom.html, 2 February 2000.</ref><ref>Statutes at Large 1845, 21.</ref>

This version is carried throughout the 19th Century, in such legal treatises as Joseph Story's Commentaries on the Constitution of the United States (1833) and Thomas Cooley's Principles of Constitutional Law (1898). It is also transcribed in this manner in the 1845 Statutes at Large, although the term "state" is capitalized in that text. The latter is the official source for acts of Congress.<ref>Commentaries on the Constitution of the United States. The Constitution Society. http://www.constitution.org/js/js_344.htm, 18 February 2000.</ref><ref>Quotes from Constitutional Commentators. Gun Cite. http://www.guncite.com/gc2ndcom.html, 2 February 2000.</ref><ref>Statutes at Large 1845, 21.</ref>

This version still appears today, as is the case with the annotated version of the Constitution they sponsored on the Government Printing Office web site (1992, supplemented in 1996 and 1998). The Second Amendment is shown as reading:

This version still appears today, as is the case with the annotated version of the Constitution they sponsored on the Government Printing Office web site (1992, supplemented in 1996 and 1998). The Second Amendment is shown as reading:

(The Senate-sponsored GPO site does carry a "literal print" of the amendments to the Constitution showing the Second Amendment with the additional commas. The punctuation and capitalization of the amendments transcribed there are the same as those found on the parchment copy displayed in the Rotunda of the National Archives.)<ref>Text of the Amendments (Literal Print). The Constitution of the United States of America. http://www.access.gpo.gov/congress/senate/constitution/conamt.html, 18 February 2000.</ref>

(The Senate-sponsored GPO site does carry a "literal print" of the amendments to the Constitution showing the Second Amendment with the additional commas. The punctuation and capitalization of the amendments transcribed there are the same as those found on the parchment copy displayed in the Rotunda of the National Archives.)<ref>Text of the Amendments (Literal Print). The Constitution of the United States of America. http://www.access.gpo.gov/congress/senate/constitution/conamt.html, 18 February 2000.</ref>

Thus, many scholars argue that correct rendition of the Second Amendment carries but a single comma, after the word "state." It was in this form that those twenty-seven words were written, agreed upon, passed, and ratified.

Thus, many scholars argue that the correct rendition of the Second Amendment carries but a single comma, after the word "state." It was in this form that those twenty-seven words were written, agreed upon, passed, and ratified.

Why the Commas are Important

Why the Commas are Important

==Liberal targeting==

==Liberal targeting==

[[Liberal]]s have made various efforts to subvert the Second Amendment by enacting unconstitutional gun laws that restrict the ability of individuals to protect themselves against the excesses of [[government]]. Examples include:

[[Liberal]]s have made various efforts to subvert the Second Amendment by enacting unconstitutional gun laws that restrict the ability of individuals to protect themselves against the excesses of [[government]]. Examples include:

* news reports appealing predominately to emotion in the aftermath of mass shootings while ignoring merits of self-defense  

* news reports appealing predominately to emotion in the aftermath of mass shootings while ignoring the merits of self-defense  

* celebrity-showings demanding a plan to end mass shootings

* celebrity-led events demanding a plan to end mass shootings

* gun "buy back" programs officiated by city police

* gun "buy back" programs officiated by city police

The drafters of the Second Amendment probably had muskets and handguns in mind, but courts are now struggling to define the weapons covered by the "right to bear arms" in the 21st Century.

The drafters of the Second Amendment probably had muskets and handguns in mind, but courts are now struggling to define the weapons covered by the "right to bear arms" in the 21st Century.

For example, the Connecticut Supreme Court in [http://jud.ct.gov/external/supapp/Cases/AROcr/CR315/315CR113.pdf''State v. DeCiccio'' (2015)] upheld the constitutionality of a state law prohibiting the transportation of a police batton or dirk knife in a motor vehicle. Yet, the Court struck down the statute to the extent that it infringed on the defendant's right to transport them between his old and new residences.

For example, the Connecticut Supreme Court in [http://jud.ct.gov/external/supapp/Cases/AROcr/CR315/315CR113.pdf ''State v. DeCiccio'' (2015)] upheld the constitutionality of a state law prohibiting the transportation of a police baton or dirk knife in a motor vehicle. Yet, the Court struck down the statute to the extent that it infringed on the defendant's right to transport them between his old and new residences.

There are also lower court cases finding Second Amendment protection for tasers, billy clubs, switchblades and other weapons that are less lethal than handguns.<ref>{{cite web|url=https://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/12/16/second-amendment-protects-dirk-knives-and-police-batons/|title=Second Amendment protects dirk knives and police batons|first=Eugene |last=Volokh |date=December 16, 2014|work=Washington Post|accessdate=February 7, 2015}}</ref>

There are also lower court cases finding Second Amendment protection for tasers, billy clubs, switchblades and other weapons that are less lethal than handguns.<ref>{{cite web|url=https://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/12/16/second-amendment-protects-dirk-knives-and-police-batons/|title=Second Amendment protects dirk knives and police batons|first=Eugene |last=Volokh |date=December 16, 2014|work=Washington Post|accessdate=February 7, 2015}}</ref>