Joe Sylvester wrote:

>
> There is nothing in the Rhode Island Constitution's RKBA provison about
the
> militia. The court looked to the federal Constitutional provision and to
> those of some other states.
>
> Their reasoning, if one can call it that, dealt with the meaning of "to
> bear" and decided it ony applied to a military, and thus militia, context.
> This of course ignores the provisions in yet other state Constitutions
which
> explicitly apply to "bearing arms in defense of themselves and the state".

There is a good reason why there is nothing in Rhode Island's RKBA provision
about the militia: by the time the RI constitution was adopted (1842), it
was well established that RI did not have sovereign power over its own
militia. By contrast, the Massachusetts "common defense" RKBA provision
dated from 1780, when that commonwealth had the undisputed sovereign power
to embody its militia. So it may make sense that the Rhode Island framers
omitted "militia" because they knew the state could ultimately not confer
that status, and they intended to protect private arms-keeping and
arms-bearing as a state right.

By 1842, Congress had exercised its militia powers for 50 years; the U.S.
Supreme Court had for 22 years held that Congress had 'occupied the field'
of militia law and preempted state law (Houston v. Moore); the Supreme Court
had also rejected (in Martin v. Mott, 1827) the militia-related
state-sovereignty arguments raised the Hartford Convention states (which
included Rhode Island). Also by 1842, the states were starting to exempt
large classes of citizens from militia duty, and Massachusetts found it
necessary (in 1839) to obtain an advisory opinion of the Supreme Judicial
Court to confirm that such exemptions were consistent with federal law, and
thus within the constitutional power of the states.

Reading "militia" into the Rhode Island RKBA provision is not simply an act
of "contextualizing," it binds the court's decision to militia law, a
distinct area of law which received no consideration in the case. The
federal "collectivist" 2nd Am decisions make the federal right contingent on
"militia" status that Congress can withhold. Taking that as the basis for a
state "right" begs an explanation as to whether anything at all is protected
from the state, and how it is protected.

Sorely missing from the RI opinion is any legal discussion of "militia"
status, or any effort to identify how that status can be conveyed on
citizens. Despite the court's holding being based on that point, the opinion
is devoid of meaningful militia law discussion. It would be remiss in a law
student to make such assertions without at least consulting a hornbook about
militia law. Surely some brief-writer will direct the other courts'
attention to this in the future.

Norman Heath











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