Comments on the legal history of the 2nd
by
Matt Giwer
No, I am not going to discuss it, I am going to comment upon
it. Specifically, I am comment upon the lack of it. For a
century an a half its case history was second only to that of the
3rd in dirth. The meaning of the 3rd was clear and cases of its
violation were apparently negligable.
Similarly the meaning of the 2nd was clear and cases of the
violation of its presumed meaning were negligable. In fact until
Miller, in response to the first federal weapons ban, the only
references are in passing in cases not related to 2nd amendment
issues. Even the 1st amendment can not make a claim of lasting
so long without challenge even for today's "clearest" clauses.
In the case of what are given as axiomatic rights upon which
a government is based it is prudential, when there is ambiguity,
to err on the side of those rights. That direction of "error" is
the clear history of the 1st amendment. It is clearly the
opposite approach that applies to the 4th amendment (search and
siezure) so there is no guidance as to an accepted direction of
error.
For example in the 1st we err in the direction of benefit to
society and most solidly reject the idea that speech or religion
or the press control can be of benefit to society. In the 4th we
are asked to make fine distinctions between the benefits to the
individual and those of the state rather than rejecting the idea
that any benefit to the state is illusory as we do in the
suppression of speech.
But in the 2nd we are facing a different issue. A criteria
has been introduced that exists in no other form for not other
right. That criteria is that crime can be reduced by the
restriction of a right. This is unparalleled in any other
amendment.
At one extreme we have a finding that even the explicit,
verbal advocacy of the overthrow of the government by force is
protected speech. On the other hand we have amazingly fine
quibblings over search and seizure such as what constitutes plain
sight and what constitutes consent. In the former case it is
held that advocacy of violence is protected but in the latter we
hold that there are cases where the guilty should go free.
In regard to the 2nd we have the presumption that fewer
crimes will occur if certain types of weapons are banned and
certain controls are imposed and therefore a right may be
infringed for the good of everyone.
Depending upon which political extreme a person belongs to
either violent movies or violent speech, do or do not incite
violence. (It is noted there is no solid evidence for any of the
four possibilities in this example.) However, it is held, again
without solid evidence, that the prior suppression of certain
types of arms, unlike prior suppression of speech, will prevent
future crimes or violent behavior.
The very lack of such a connection for over a century
certainly speaks volumes for people in times when had much more
direct knowledge of their neighbors and their habits than we do
today. Rather the connection between gun prohibitions and crime
in socially neutral environment (ignoring the first gun laws were
to prevent ownership by freed slaves and later applied against
union members) was as a result of the consequences of
Prohibition.
Machineguns and automatic weapons were outlawed because they
were weapons of choice by organized crime. Consider that
machineguns were used in the St. Valentine's Day massacre and
fewer died that on a good weekend execution slaying in Washington
DC. Consider that the .22 handgun has replaced the short
barrelled shotgun as the close assassination weapon of choice
because it is better. And then consider the clear evidence that
banning those two weapons had no justification even in the
purported connection with crime.
Despite the dirth of 2nd amendment cases, this law caused
the first one related to today's issues in which the defense was
not represented. It involved a ban on certain weapons that were
popular with organized crime but in fact had no relation to crime
unless one holds both that they obeyed the law and found no
substitutes, both of which are not supported by any solid
evidence.
The next federal law was in 1968 in response to two
assassinations and it was freely admitted, as have all such
instances since including in 1994, that the law have done nothing
to have prevented them.
Thus we have a criteria for the 2nd that religious zealots
would like to apply to the 1st, that the unproven presumption of
harm to society outweighs the individual right. It is not as
though millions of non-criminals had become criminals for the
sole cause of gun ownership. Nor is it evidenciary that
criminals are criminals solely because of their access to guns.
And there is certainly no evidence that criminals obey gun laws
only.
So here we have the 2nd attacked upon grounds that would be
laughed out of court if applied to the 1st. R rated movies cause
crime therefore they must be controlled if not banned. Graphic
violence causes real violence therefore it can not be permitted
in interstate commerce. Assualt weapons cause crime and
therefore must be banned from interstate commerce.
There is also the implication that guns make crime possible
even though the per capita rate of violent crime and been
decreasing for nearly a century and only the preference for guns
over other weaopns has increased. The argument for banning guns
today is no better than an argument for banning knives a century
ago based upon crime prevention.
It was not until the equivalent of prior censorship was
introduced into the 2nd amendment. Before then gun owners did
not have to question their right to own guns. Before then there
was no one questioning their rights. The lack of challenges
attests to it.
The 2nd differs from the 1st in that prior restraint was
considered reasonable for the 1st. The 2nd brought the same
response ab initio to prior censorship being applied whereas the
1st had to discover new variations of what was protected before
it developed a legal history.
As in the history of the ACLU it made little progress for
decades in discovery these new variations. It started with the
Supreme Court refusing to hear such cases and when it did,
deciding upon the narrowest of grounds, as in 2nd cases, against
the 1st.
And this leaves us where we are today with the 2nd. There
exists no unambiguous decision regarding the 2nd amendment.
Miller did not state "if there were military utility then it
would be protected" rather it was written inverse to that, "in
the absence of." The desire here is to obtain a clear case to be
heard by the Supreme Court in which only an unambiguous decision
can be made, such as "separate is not equal."
Those against gun ownership on personal grounds such as
Handgun Control Incorporated file briefs urging the Supreme Court
not to hear such cases. The NRA encourages the court to hear
such cases and requests a decision based upon 2nd amendment
grounds.
The ideological lines are drawn and it is certainly desired
those wishing the matter to be decided on the merits of the case
and the constitution to have such a case heard and the
ambiguities resolved.
The current court is encouraging in that it issued the first
limitation upon the interstate commerce clause in decades. Given
the last case the "diner in the middle of the state" case could
be overturned. That it might be willing to take on such a minor
case as a handful of useless but burdensome laws it to be
expected.