"Heller as Hubris, and How McDonald v. City of Chicago May Well Change
the Constitutional World as We Know It" (
http://hq.ssrn.com/Journals/RedirectClick.cfm?url=http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1607092&partid=47512&did=74653&eid=98131682
) 
Santa Clara Law Review, Vol. 50, No. 4, 2010 (
http://hq.ssrn.com/Journals/RedirectClick.cfm?url=http://papers.ssrn.com/sol3/PIP_Journal.cfm?pip_jrnl=243257&partid=47512&did=74653&eid=98131682
) 

WILLIAM G. MERKEL (
http://hq.ssrn.com/Journals/RedirectClick.cfm?url=http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=367057&partid=47512&did=74653&eid=98131682
), Washburn University - School of Law
Email: [email protected]


This article critiques the jurisprudential philosophy underlying
Justice Scalia’s opinion in District of Columbia v. Heller, in which the
Supreme Court for the first time enforced a private right to weapons
possession under the Second Amendment. The article anticipates the
likely incorporation of that newly minted right against the states in
McDonald v. City of Chicago, a case heard by the Supreme Court in the
spring of 2010, and argues that the original understanding of the Second
and Fourteenth Amendments cannot easily be reconciled with a judicially
enforceable right to weapons possession unrelated to service in the
lawfully established militia. In the process, the article calls into
question glib popular and judicial assumptions believed to legitimize
judicial review, and suggests that judicial veto of legislatively
determined policy choices requires a far more cogent theoretical
foundation than that provided by Justice Scalia’s fetishistic and
idolatrous adherence to caricatured visions of an “original public
meaning” that allegedly held sway when constitutional text was proposed
and ratified. 
 

*****************************************************************************************
Professor Joseph Olson, J.D., LL.M.                                  
o-   651-523-2142  
Hamline University School of Law (MS-D2037)                    f-   
651-523-2236
St. Paul, MN  55113-1235                                               
 c-   612-865-7956
[email protected]                             
http://law.hamline.edu/node/784                      
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