District of Columbia v. Heller
Background
The case of District of Columbia v. Heller is a landmark decision by the U.S. Supreme Court that fundamentally shaped the interpretation of the Second Amendment. Decided on June 26, 2008, the case addressed the constitutionality of the District of Columbia's handgun ban and its requirement that firearms in the home be kept nonfunctional even when necessary for self-defense. This decision marked the first time the Supreme Court explicitly affirmed an individual's right to possess firearms unconnected with service in a militia for traditionally lawful purposes, such as self-defense within the home.
Legal Context
The Second Amendment
The Second Amendment of the United States Constitution, ratified in 1791, states: "A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed." Historically, the interpretation of this amendment has been the subject of intense debate. The amendment's language has led to differing views on whether it protects an individual's right to own firearms or a collective right related to state militias.
Preceding Case Law
Before District of Columbia v. Heller, the Supreme Court had not definitively ruled on the individual versus collective rights interpretation of the Second Amendment. The 1939 case of United States v. Miller was often cited, where the Court upheld a federal law regulating sawed-off shotguns, suggesting that the Second Amendment did not guarantee an individual right to bear arms unless it had a reasonable relationship to the preservation or efficiency of a well-regulated militia.
Case History
District of Columbia Gun Control Laws
The District of Columbia had some of the strictest gun control laws in the United States. The Firearms Control Regulations Act of 1975 prohibited residents from owning handguns, required all firearms to be registered, and mandated that firearms in the home be kept unloaded and disassembled or bound by a trigger lock. These regulations effectively banned the use of firearms for self-defense within the home.
Initiation of the Case
The case began when Dick Anthony Heller, a licensed special police officer in Washington, D.C., applied for a registration certificate for a handgun he wished to keep at home. His application was denied under the District's handgun ban. Heller, along with five other plaintiffs, filed a lawsuit challenging the constitutionality of the District's gun laws, arguing that they violated his Second Amendment rights.
Lower Court Decisions
The United States District Court for the District of Columbia initially dismissed the case, ruling that the Second Amendment did not provide an individual right to bear arms. However, the United States Court of Appeals for the District of Columbia Circuit reversed this decision, holding that the Second Amendment does protect an individual's right to possess firearms and that the District's regulations were unconstitutional.
Supreme Court Decision
Majority Opinion
The Supreme Court, in a 5-4 decision, affirmed the Court of Appeals' ruling. Justice Antonin Scalia authored the majority opinion, which held that the Second Amendment protects an individual's right to possess a firearm unconnected with service in a militia and to use that arm for traditionally lawful purposes, such as self-defense within the home. The Court struck down the District's handgun ban and the requirement that firearms in the home be kept nonfunctional, as they violated the Second Amendment.
Scalia's opinion engaged in an extensive historical analysis of the Second Amendment's text and context, concluding that the right to bear arms was understood to be an individual right at the time of the founding. The opinion emphasized that the right is not unlimited and does not preclude the existence of certain longstanding prohibitions on the possession of firearms by felons and the mentally ill, or laws forbidding the carrying of firearms in sensitive places such as schools and government buildings.
Dissenting Opinions
Justice John Paul Stevens wrote a dissenting opinion, joined by Justices David Souter, Ruth Bader Ginsburg, and Stephen Breyer, arguing that the Second Amendment was intended to protect the right to bear arms for military purposes and did not curtail the government's ability to regulate civilian use of firearms. Justice Breyer also wrote a separate dissent, expressing concern that the majority's decision would lead to a proliferation of gun rights litigation and complicate the ability of legislatures to address gun violence.
Implications and Impact
Legal and Political Repercussions
The Heller decision had profound implications for gun rights and gun control in the United States. It established a legal precedent for the individual right to bear arms, influencing subsequent cases and legislation. The ruling has been cited in numerous legal challenges to gun control measures, shaping the landscape of Second Amendment jurisprudence.
Subsequent Cases
Following Heller, the Supreme Court further clarified the scope of the Second Amendment in McDonald v. City of Chicago, extending the individual right to bear arms to state and local governments through the doctrine of incorporation under the Fourteenth Amendment.
Societal Impact
The decision has been a focal point in the ongoing debate over gun control in the United States. Advocates for gun rights have hailed the ruling as a victory for individual liberties, while gun control proponents have expressed concern over its potential to hinder efforts to reduce gun violence.