Right to keep and bear arms in the United States

The American understanding of the right to keep and bear arms was influenced by the 1689 English Bill of Rights, an Act of Parliament, which also dealt with personal defence by Protestant English subjects.

The Bill of Rights did not create a new right to have arms but rather rescinded and deplored acts of the deposed King James II, a Roman Catholic, who had forced the disarming of Protestants, while arming and deploying armed Catholics contrary to law, among other alleged violations of individual rights. The Bill of Rights provided that Protestants could bear arms for their defence as permitted by law. It also established that the power to regulate the right to bear arms belonged to Parliament, not the monarch.[8]

Sir William Blackstone wrote in the eighteenth century about the right to have arms being auxiliary to the "natural right of resistance and self-preservation", but conceded that the right was subject to their suitability and allowance by law.

The fifth and last auxiliary right of the subject, that I shall at present mention, is that of having arms for their defence, suitable to their condition and degree, and such as are allowed by law. Which is also declared by the same statute and is indeed a public allowance, under due restrictions, of the natural right of resistance and self-preservation, when the sanctions of society and laws are found insufficient to restrain the violence of oppression.[9]

Gun show, in the U.S.

After the 1776 American Revolution, one of the first legislative acts undertaken by most of the newly independent states was to adopt a "reception statute" that gave legal effect to the existing body of English common law to the extent that the legislation or the constitution had not explicitly rejected English law.[10]

For example, The Reception Statute of Virginia (1776):

And be it further ordained, That the common law of England, all statutes or acts of Parliament made in aid of the common law prior to the fourth year of the reign of King James the first, and which are of a general nature, not local to that kingdom, together with the several acts of the General Assembly of this colony now in force, so far as the same may consist with several ordinances, declarations, and resolutions of the General Convention, shall be the rule of decision, and shall be considered as in full force, until the same shall be altered by the legislative power of this colony.[11]

The Reception statute of Pennsylvania (1777):

( 1.) Each and every one of the laws or acts of general assembly, that were in force and binding on the inhabitants of the said province on the 14th day of May last, shall be in force and binding on the inhabitants of this state, from and after the 10th day of February next, as fully and effectually, to all intents and purposes, as if the said laws, and each of them, had been made or enacted by this general assembly . . . and the common law and such of the statute laws of England, as have heretofore been in force in the said province, except as hereafter excepted. (2.) Provided always, that so much of every law or act of general assembly of the province aforesaid, . . . as declares, orders, directs or commands any matter or thing repugnant to, against, or inconsistent with the constitution of this commonwealth, is hereby declared not to be revived, but shall be null and void, and of no force or effect; and so much of the statute laws of England aforesaid relating to felonies, as takes notice of or relates to treason or misprision of treason, or directs the style of the process in any case whatsoever, shall be, and is hereby declared, of no force or effect, anything herein contained to the contrary notwithstanding.[12]

The New York Constitution of 1777 provides that:

[S]uch parts of the common law of England, and of the statute law of England and Great Britain, and of the acts of the legislature of the colony of New York, as together did form the law of the said colony on the 19th day of April, in the year of our Lord one thousand seven hundred and seventy-five, shall be and continue the law of this State, subject to such alterations and provisions as the legislature of this State shall, from time to time, make concerning the same.[13]

Over time, as new states were formed from federal territories, the territorial reception statutes became obsolete and were re-enacted as state law. For example, a reception statute enacted by legislation in the state of Washington states:

The common law, so far as it is not inconsistent with the Constitution and laws of the United States, or of the state of Washington nor incompatible with the institutions and condition of society in this state, shall be the rule of decision in all the courts of this state."[14]

Missouri's reception of the common law is codified under Missouri Revised Statutes Section 1.010 (2000). The statute reads:

The common law of England and all statutes and acts of parliament made prior to the fourth year of the reign of James the First, of a general nature, which are local to that kingdom and not repugnant to or inconsistent with the Constitution of the United States, the constitution of this state, or the statute laws in force for the time being, are the rule of action and decision in this state, any custom or usage to the contrary notwithstanding, but no act of the general assembly or law of this state shall be held to be invalid, or limited in its scope or effect by the courts of this state, for the reason that it is in derogation of, or in conflict with, the common law, or with such statutes or acts of parliament; but all acts of the general assembly, or laws, shall be liberally construed, so as to effectuate the true intent and meaning thereof.[15]

U.S. gun sales have risen steadily in the 21st century, peaking in 2020 during the COVID-19 pandemic.[16]

In United States v. Cruikshank (1876), the U.S. Supreme Court recognized that the right to arms preexisted the Constitution and in that case and in Presser v. Illinois (1886) recognized that the Second Amendment protected the right from being infringed by Congress. In United States v. Miller (1939), the Court again recognized that the right to arms is individually held and, citing the Tennessee case of Aymette v State, indicated that it protected the right to keep and bear arms that are "part of the ordinary military equipment" or the use of which could "contribute to the common defense." In its first opportunity to rule specifically on whose right the Second Amendment protects, District of Columbia v. Heller (2008), the Court ruled that the amendment protects an individual right "to keep and carry arms in case of confrontation," not contingent on service in a militia, while indicating, in dicta, that restrictions on the possession of firearms by felons and the mentally ill, on the carrying of arms in sensitive locations, and with respect to the conditions on the sale of firearms could pass constitutional muster. In the 2010 case of McDonald v. Chicago, the Court applied incorporation doctrine to extend the Second Amendment's protections nationwide

The people's right to have their own arms for their defense is described in the philosophical and political writings of Aristotle, Cicero, John Locke, Machiavelli, the English Whigs and others.[17] Though possessing arms appears to be distinct from "bearing" them, the possession of arms is recognized as necessary for and a logical precursor to the bearing of arms.[18] Don Kates, a civil liberties lawyer, cites historic English usage describing the "right to keep and bear their private arms."[19] Likewise, Sayoko Blodgett-Ford notes a non-military usage of the phrase in a pamphlet widely circulated by the dissenting minority dating from the time of the Pennsylvania ratifying convention for the U.S. Constitution:

[T]he people have a right to bear arms for the defense of themselves and their own state, or the United States, or the purpose of killing game; and no law shall be passed for disarming the people or any of them, unless for crimes committed ...[20]

In commentary written by Judge Garwood in United States v. Emerson, the United States Court of Appeals for the Fifth Circuit concluded in 2001 that:[21]

... there are numerous instances of the phrase 'bear arms' being used to describe a civilian's carrying of arms. Early constitutional provisions or declarations of rights in at least some ten different states speak of the right of the 'people' [or 'citizen' or 'citizens'] 'to bear arms in defense of themselves [or 'himself'] and the state,' or equivalent words, thus indisputably reflecting that under common usage 'bear arms' was in no sense restricted to bearing arms in military service. See Bliss v. Commonwealth, 13 Am. Dec. 251, 12 Ky. 90 (Ky. 1822).[22]

Similarly, in a released Senate report on the Right to Keep and Bear Arms, Senator Orrin Hatch, chairman, U.S. Senate Judiciary Committee, Subcommittee on the Constitution, states:

They argue that the Second Amendment's words "right of the people" mean "a right of the state" – apparently overlooking the impact of those same words when used in the First and Fourth Amendments. The "right of the people" to assemble or to be free from unreasonable searches and seizures is not contested as an individual guarantee. Still they ignore consistency and claim that the right to "bear arms" relates only to military uses. This not only violates a consistent constitutional reading of "right of the people" but also ignores that the second amendment protects a right to "keep" arms. "When our ancestors forged a land "conceived in liberty", they did so with musket and rifle. When they reacted to attempts to dissolve their free institutions, and established their identity as a free nation, they did so as a nation of armed freemen. When they sought to record forever a guarantee of their rights, they devoted one full amendment out of ten to nothing but the protection of their right to keep and bear arms against governmental interference. Under my chairmanship the Subcommittee on the Constitution will concern itself with a proper recognition of, and respect for, this right most valued by free men.[23]

Likewise, the U.S. Supreme Court ruled in District of Columbia v. Heller (2008), No. 07-290, that "[t]he 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."[24]

Some historians have argued that prior to and through the 18th century, the expression "bear arms" appeared exclusively in military contexts, as opposed to the use of firearms by civilians.[25][26][27][28]

In late-eighteenth-century parlance, bearing arms was a term of art with an obvious military and legal connotation. ... As a review of the Library of Congress's data base of congressional proceedings in the revolutionary and early national periods reveals, the thirty uses of 'bear arms' and 'bearing arms' in bills, statutes, and debates of the Continental, Confederation, and United States' Congresses between 1774 and 1821 invariably occur in a context exclusively focused on the army or the militia.[29]

However, this conclusion is disputed and may be due to selection bias, which arises from the use of a limited selection of government documents that overwhelmingly refer to matters of military service.[30] Commenting on this previous research, other historians note:

Searching more comprehensive collections of English language works published before 1820 shows that there are a number of uses that ... have nothing to do with military service ... [and] The common law was in agreement. Edward Christian's edition of Blackstone's Commentaries that appeared in 1790s described the rights of Englishmen (which every American colonist had been promised) in these terms 'everyone is at liberty to keep or carry a gun, if he does not use it for the [unlawful] destruction of game.' This right was separate from militia duties.[30]

The Oxford English Dictionary defines the term to bear arms as: "to serve as a soldier, do military service, fight," dating to about 1330.

Garry Wills, author and history professor at Northwestern University, has written of the origin of the term bear arms:

By legal and other channels, the Latin "arma ferre" entered deeply into the European language of war. Bearing arms is such a synonym for waging war that Shakespeare can call a just war " 'justborne arms" and a civil war "self-borne arms." Even outside the special phrase "bear arms," much of the noun's use echoes Latin phrases: to be under arms (sub armis), the call to arms (ad arma), to follow arms (arma sequi), to take arms (arma capere), to lay down arms (arma pœnere). "Arms" is a profession that one brother chooses the way another choose law or the church. An issue undergoes the arbitrament of arms."..."One does not bear arms against a rabbit ...".[31]

Garry Wills also cites Greek and Latin etymology:

..."Bear Arms" refers to military service, which is why the plural is used (based on Greek 'hopla pherein' and Latin 'arma ferre') – one does not bear arm, or bear an arm. The word means, etymologically, 'equipment' (from the root ar-* in verbs like 'ararisko', to fit out). It refers to the 'equipage' of war. Thus 'bear arms' can be used of naval as well as artillery warfare, since the "profession of arms" refers to all military callings.[32]

Historically, the right to keep and bear arms, whether considered an individual or a collective or a militia right, did not originate fully formed in the Bill of Rights in 1791; rather, the Second Amendment was the codification of the six-centuries-old responsibility to keep and bear arms for king and country that was inherited from the English Colonists that settled North America, tracing its origin back to the Assize of Arms of 1181 that occurred during the reign of Henry II. Through being codified in the United States Constitution, the common law right was continued and guaranteed for the People, and statutory law enacted subsequently by Congress cannot extinguish the pre-existing common law right to keep and bear arms.[33]

The Second Amendment to the United States Constitution refers to a pre-existing right to keep and bear arms:

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.[34]

The right is often presented in the United States as being an unenumerated, pre-existing right, such as provided for by the Ninth Amendment to the United States Constitution,[33] interpreted by some as providing for unenumerated rights, and therefore implicitly a right to keep and bear arms:

The enumeration in the Constitution, of certain rights shall not be construed to deny or disparage others retained by the people.

Some have seen the Second Amendment as derivative of a common law right to keep and bear arms; Thomas B. McAffee & Michael J. Quinlan, writing in the North Carolina Law Review said "... Madison did not invent the right to keep and bear arms when he drafted the Second Amendment – the right was pre-existing at both common law and in the early state constitutions."[35]

Akhil Reed Amar similarly notes the basis of Common Law for the first ten amendments of the U.S. Constitution, "following John Randolph Tucker's famous oral argument in the 1887 Chicago anarchist case, Spies v. Illinois":

Though originally the first ten Amendments were adopted as limitations on Federal power, yet insofar as they secure and recognize fundamental rights – common law rights – of the man, they make them privileges and immunities of the man as citizen of the United States ...[36]

Uviller and Merkel hold that the right to bear arms was not reserved for the state, but rather was an individual and personal right for arms only to the extent needed to maintain a well regulated militia to support the state. They also hold that a militia recognizable to the framers of the Constitution has ceased to exist in the United States resulting from deliberate Congressional legislation and also societal neglect; nonetheless, "Technically, all males aged seventeen to forty-five are members of the unorganized militia, but that status has no practical legal significance."[37][38]

A few academic writers published their opinions in several works:

From the text as well as a fair understanding of the contemporary ethic regarding arms and liberty, it seems to us overwhelmingly evident that the principal purpose of the Amendment was to secure a personal, individual entitlement to the possession and use of arms. We cannot, however, (as the individual rights contingent generally does) disregard entirely the first part of the text proclaiming a well regulated militia necessary to the security of a free state.[39]

... we understand the Second Amendment as though it read: "Inasmuch as and so long as a well regulated Militia shall be necessary to the security of a free state and so long as privately held arms shall be essential to the maintenance thereof, the right of the people to keep and bear arms shall not be infringed." "..to us, the language of the Amendment cannot support a right to personal weaponry independent of the social value of a regulated organization of armed citizens.[40] [41][42]

In the century following the ratification of the Bill of Rights, the intended meaning and application of the Second Amendment drew less interest than it does in modern times.[43] The vast majority of regulation was done by states, and the first case law on weapons regulation dealt with state interpretations of the Second Amendment. A notable exception to this general rule was Houston v. Moore, 18 U.S. 1 (1820), where the Supreme Court mentioned the Second Amendment in an aside.[44]

The Second Amendment of the United States Constitution is a federal provision. In 2010, this "fundamental" and "individual" right was "fully incorporated" with the 14th Amendment per the SCOTUS ruling made in McDonald v. City of Chicago, which upheld the prior opinion made in District of Columbia v. Heller. Each of the fifty states also has its own state constitution. Forty-four states have chosen to explicitly embody a right to bear arms into their state constitutions.[47] Each of the state constitutions, state laws, and state courts addresses the state-based right to bear arms distinctly within its respective jurisdictions.[48] The degree and the nature of the protection, prohibition, and regulation at the state level varies from state to state. The District of Columbia, not being a state, falls within the federal jurisdiction.

Approximately thirty-one states have explicitly chosen to include the right to arms for "individual right", "defense of self", "defense of home" or similarly worded reasons. Approximately thirteen states, as with the U.S. Constitution, did not choose to explicitly include "individual", "self" or "home" wording associated with a right to bear arms for their specific states.

Approximately twenty-eight states have explicitly chosen to include the right to bear arms for "security of a free state", "defense of state", "common defense" or similarly worded reasons, as with the U.S. Constitution. Approximately sixteen states did not choose to include explicitly "free state", "defense of state" or "common defense" wording for their specific state. Whether the inclusion of these kinds of wording in state constitutions has relevance to the issue of whether implicit "individual" rights exist, or whether such rights (if any) are implicitly protected by the states' constitutions or by the U.S. Constitution's Second Amendment, remains a matter of dispute. However, since the SCOTUS has "fully incorporated" the 2nd and 14th Amendments in their 2010 opinion and order in McDonald v. City of Chicago, the right to keep and bear arms is "fully applicable" to the states and limits the states on any and all regulations and restrictions they choose to take, and federal Constitutional rights take precedence over state, local and other laws that regulate to "Right of Lawful Citizens to keep and bear Arms for self-defense, a 'central component' of the 2nd Amendment" (see McDonald v. City of Chicago (SC 2010)).

Regarding the state interpretations of these state and the federal constitutional rights to bear arms, state courts have addressed the meaning of these specific rights in considerable detail. Two different models have emerged from state jurisprudence: an individual right (defense of self or home) and a collective (defense of the state) right. The states cannot lessen or restrict any Bill of Rights guarantee that has been "fully incorporated" (American jurisprudence) and that the right that is "fully incorporated" also applies to the respective State Constitutions; again, the states can only "add to" these rights but can never "diminish" these rights by state and local laws.

U.S. opinion on gun control issues is deeply divided along political lines, as shown in this 2021 survey.[89]

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The political party that advocates most for gun rights is the Libertarian Party, who believe gun rights is a natural right for everyone. They are followed by the Republican Party, which advocates for gun rights, but support gun control measures, like red flag laws, and prohibition of certain individuals from owning guns. The Democratic Party advocates for the most gun control measures historically. Interest groups, primarily in the United States, exert political pressure for and against legislation limiting the right to keep and bear arms. This political debate in America is organized between those who seek stricter regulations and those who believe gun regulations violate the Second Amendment protection of a right to keep and bear arms.[90] The largest advocacy group in this regard is the National Rifle Association, and its political wing, the NRA Institute for Legislative Action, aside from the Libertarian Party which advocates gun rights for everyone in their political platform. Several other groups including the Gun Owners of America and the Citizens Committee for the Right to Keep and Bear Arms, while smaller in size, are also politically active.[91] Gun control advocacy groups include the Brady Campaign and Everytown for Gun Safety, which are increasingly gaining political clout and spending power.[92]

There are also socialist gun rights groups, including the Socialist Rifle Association[93] and Redneck Revolt.[94]

According to joint polls published by CNN and the SSRS Institute: A majority of Americans support stricter gun control law; 64% of Americans support stricter gun control laws, while 36% oppose it. Besides, 54% of Americans believe that such laws will reduce the number of deaths and killings of citizens with firearms, and 58% believe that the government can take effective action to prevent mass shootings.[95]

• 2nd Amendment Day
• American gun ownership
• Gun laws in the United States by state
• Second Amendment sanctuary
• Gun politics
• Index of gun politics articles
• Overview of gun laws by nation
• Right of self-defense

• Lund, Nelson (2008). "Right to Bear Arms". In Hamowy, Ronald (ed.). The Encyclopedia of Libertarianism. Thousand Oaks, CA: Sage; Cato Institute. pp. 438–440. doi:10.4135/9781412965811.n269. ISBN 978-1412965804. OCLC 750831024.

• Volokh, Eugene (ed.). "State Constitutional Right to Keep and Bear Arms Provisions". UCLA School of Law. Archived from the original on March 5, 2020. Retrieved 3 April 2020..