David Hardy wrote:

>
> Some stuff Congress just had no power to
> do, so no need to ask whether the BoR took the power away. Some have
> pointed out that the very expansive view of federal power puts
> pressure on the BoR which it was never meant to hold. For a
> government of limited powers, 8-10 amendments were enough. Look at
> the BoRs of most states, created with the assumption they would have
> general powers, and you'll see far more guarantees with lots more
> detail.

Stewart can be cited in support of the proposition that under the
Constitution a Second Amendment prohibition on federal criminalization of
gun ownership should be seen as unremarkable and entirely akin to the
repudiation of implied powers to criminalize speech, seize property without
due process, or quarter troops in homes.

I think David and I are really more or less in accord. It is true that
Wickham and progeny indicate that Congress, via the commerce power, can
limit the scope of the amendment, and Stewart does next to nothing to change
that. But Stewart does support the originalist and structuralist arguments
that the amendment protected an existing right (gun ownership) from a
non-existent federal power.

This is even more visible from the opposite perspective: the
anti-individualist argument that Madison and the rest of Congress never
intended to renounce federal power to criminalize gun possession. I've seen
cited in support of this proposition the disarming of Pennsylvanians during
the Whiskey Rebellion, "proof" that the Constitution contemplated federal
gun-banning and the Second Amendment did not prohibit same. Now that the 9th
Cir. has decided that the Constitution does not contemplate a federal power
to criminalize gun ownership, what of the argument that Madison et. al
intended to retain a federal power to criminalize gun ownership? Stewart is
in conflict with the implied-power aspect of the anti-individual model.

I'm not hidebound by originalism. But the Second Amendment is interpretively
almost a blank slate: given the dispute over Miller, it must be said that
the courts haven't established to whom the amendment applies, let alone its
scope. It has never been applied by the federal courts to any party at all;
not individuals, nor state legislatures, nor state militia. I think Stewart
confirms the structuralist inference, if not the originalist argument, that
Congress was never delegated the power to criminalize gun ownership, and
that this militates in favor of the Standard Model.

Norman Heath







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