For many decades, gun control proponents who saw their fortunes wane in legislatures from coast to coast and who were unable to get traction with Congress could at least console themselves with the thought that activist courts had their backs. The Second Amendment, after all, had been all but written out of the U.S. Bill of Rights by law professors and politically-minded judges, as cities and even the U.S. Congress increasingly adopted gun control in the Twentieth Century.
But none of that could change the text, history, or tradition of the Second Amendment, which led to an unbroken and uniquely American embrace of private gun ownership as a defense against crime and tyranny and also gave rise to the popular understanding of bearing arms as a birthright of U.S. citizenship.
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