For several decades, the lower federal courts had interpreted the Second Amendment as protecting merely a collective right of state militias.<ref>http://www.davekopel.com/2A/LawRev/35finalpartone.htm</ref> However, the US Supreme Court has always called it an individual right. The 2008 case [[US v Heller]] ruled unanimously that the Second Amendment protects an individual right.
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Some interpret the Second Amendment as protecting merely a collective right of state militias, while most interpret it as protecting an individual right that, unlike the rest of the Bill of Rights, applies to the states as well as the federal government.<ref>http://www.davekopel.com/2A/LawRev/35finalpartone.htm</ref>