I think Judge Kozinski just made a contribution to the 2nd Am debate.

The question in _Silveira_  was/is: did Congress, in adopting the Second
Amendment, waive the power to prohibit firearms possession by individuals?
(leaving aside incorporation for the moment)

And the answer in _Stewart_ is: Congress was never delegated a power to
prohibit firearms possession by individuals.

The 9th Cir. now holds that Congress was never delegated a power to regulate
firearms ownership, while paradoxically denying that the 2nd Amendment
impeded a Congressional power to regulate firearms ownership.

An originalist might address the above by pointing out that the Bill of
Rights generally guaranteed rights that Congress was considered to have no
power to infringe anyway. Either the 2nd Am guaranteed an individual right
that was unextraordinary at the time, and which Congress had no power to
regulate, or it constituted a re-opening of the contentious militia-power
question which the Federalists had already won and previously refused to
re-open. The new decision from the 9th supports the former.

Norman Heath








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