involves the fundamental relationship between citizen and state. In arriving at a

personal right the District Court embraces two confusions present in contemporary

gun rights politics: 1) between natural rights and civil rights; 2) between a personal

right and the people's right to participate in the military functions of the state. The

District Court touches on the individual right-to-arms as a right to self-defense and

strongly implies a right to revolution. This amicus will give notice to these two

dimensions of the individual right-to-arms and will introduce two other dimensions:

the libertarian fantasy and the individual right's place in contemporary political

cynicism.

District Court's personal right and find there can be no personal right of the sort

claimed. Rather than an orphan of the Bill of Rights, as suggested (fn46) by this

court in US v. Lopez, the true legacy of the Second Amendment is found in the

citizen soldiers of twentieth century selective service acts. To "bear arms" had a

military meaning (Rowland, Appendix A).

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Argument

I. THE DISTRICT COURT ERRED BY CONFUSING NATURAL RIGHTS WITH CIVIL RIGHTS TO CREATE A PERSONAL RIGHT TO ARMS INDEPENDENT OF SOVEREIGN GOVERNMENT AUTHORITY

a. The Formation of Political Community

When men enter into a state of society, they surrender up some of
their natural rights to that society, in order to insure the protection
of others; and, without such an equivalent, the surrender is void.
(Thorpe)

James Wilson, one of the 55 Framers, argued for ratification before the

Pennsylvania ratifying convention:

Civil liberty is natural liberty itself, divested only of that part which,
placed in the government, produces more good and happiness to the
community than if it had remained in the individual. (2 Elliot's
Debates 429)

The Framers and ratifiers had great concerns about the sovereign political power

they were creating, but they had no illusions that they were creating a sovereign

public authority (Adams, p. 474-5):

It must be made a sacred maxim, that the militia obey the executive
power, which represents the whole people in the execution of laws. To
suppose arms in the hands of the citizens, to be used at individual
discretion, except in private self defense, or by partial orders of towns,
counties, or districts of a state, is to demolish every constitution, and
lay the laws prostrate, so that liberty can be enjoyed by no man is a
dissolution of the government. The fundamental law of the militia is,
that it be created, directed, and commanded by the laws, and ever for
the support of the laws.

The English historian Richard Tawney exquisitely contrasted public authority and

secular sovereignty in the West with the political culture of China:

The first problem, which lies behind all questions of particular reforms,
is vast and fundamental. It is not who shall govern the State, but
whether there shall be a State at all. It is whether public power shall

exist. China has known no Roman Empire. The idea of a sovereign, of
an even pressure of law, of the impersonal majesty of an authority to
which, and not to his family and his friends, the individual owes
allegiance, of the Res publica, which in Europe men remembered dimly
when all had slipped and struggled back to as to a rock that idea is
not an ancient part of the nation's mental furniture...

A majority held in restraint by constitutional checks and limitations,
and always changing easily with deliberate changes of popular opinion
and sentiments, is the only true sovereign of a free people. Who ever
rejects it does, of necessity, fly to anarchy or to despotism.

The central idea of secession is the essence of anarchy.

The checks and limitations on sovereignty are contained within the legal political

order itself through separation of power, checks and balances, a bill of rights,

regular elections, and free institutions that provide civic enlightenment and

vigilance. In present gun rights consciousness, an armed populace, called the

"sedentary" or "unorganized" militia, possessing a personal right-to-arms and

unbeholden to any public authority, is the ultimate check on state power. (Appendix

B) A contingent of extralegal armed force, active or passively threatening, created

by a personal right, is not a check or limitation on sovereignty. It is a rival

sovereignty. An individual right that creates the vague threat of an armed check or

limitation on sovereignty is the essence of political cynicism, the opposite of a civic

culture of public trust created by common agreement on the fundamental law of a

constitution.

constituted, the state is public authority and public authority is sovereign. The

personal right the District Court and the literature it cites seek to find in the Second

Amendment is the right to be armed prior to and independent of any law or state

interest. Carried to its logical conclusion, the right denies the consent to be

governed and repudiates the very concept of sovereign public authority created in political community.

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b. To Bear Arms

collective had a different purpose. To "bear arms" describes a military function.

(Rowland, Appendix A) The militia was an alternative form of military

organization to the regular army. John Adams' "private self-defense" (supra, p. 4)

was not mentioned in the states' militia amendment proposals (Rowland,

dissertation, p. 401). The larger context was the republican right of the people to

participate in the military functions of the state rather than leave those functions up

to the King's regular army, "a separate order of the state" (Dist. Ct. Op. p. 12),

which in the eighteenth century was usually composed of mercenaries, foreigners,

and/or social misfits. The militiamen were citizen soldiers rooted in their

communities. (Cress) The very quotes the District Court provides describe the

militia explicitly as an opposing concept to the regular army. The right was not a

right against any and all government. The Militia Act of 1792, enacted by the same

people who ratified the Second Amendment, expressed the eighteenth century

concept of the militia and what it imposed on individuals. The Militia Act required

the states to "enroll"— that is, register— militiamen. (Appendix C). Militia duty

was conscript duty. The regular army was not. The dozens of state militia acts that

followed from the national act were loaded with rules imposed on gun owners.

There were no protections mentioned for a personal right to be armed independent

of militia that the District Court and others seek to find.

sovereign public authority. Consistent with the "right to imploy his force," the

Constitution makes the President the Commander-in-Chief of the militia and gives

Congress the authority to call out the militia. The states, the President and the

Congress have a right and need to know who the militia are and what the militia

resources, as a national resource, are. That requirement denies any right to be

armed prior to and independent of law and government.

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c. The Right to Revolution: The Hidden Content

The District Court describes the individual right to bear arms, embodied in

the militia institution, as the crucial factor in the Revolution that prevailed over the

British Army and asserts from this that "through the Constitution" "the American

founders sought to codify the individual right to bear arms." (Dist. Ct. Op., p. 11)

It is strongly implied in the District Court's Opinion and explicitly stated by others

that the individual right to arms is a right to revolution or a right to threaten

revolution. The King put it accurately that the Revolution was treason, but the

period 1774-76 was a revolutionary situation. The Declaration of Independence

was a moral justification for a revolution that had already taken place in spirit.

There was a critical mass in the general population to support the treason. The

Declaration invoked a natural right not a civil right. The Constitution instituted new

government. It secures civil rights. The District Court embraces the great confusion

between natural rights and civil rights. The Constitution would be perverted if it

defined treason as the waging of war against the United States and then guaranteed

a civil right to do the same.

status of revolutionary and military competence it did not have. The Continental

Army with much help from the French Army won the War of Independence.

Observations from that period on militia deficiencies are legend. (Appendix C).

into the Second Amendment. The assertions are explicit (expanded context in

(Appendix D):

Sue Wimmershoff-Caplan, a member of the National Rifle Association's National

Board, wrote in "The Founders and the AK-47," Washington Post, July 6, 1989:

The private keeping of hand-held personal firearms is within the
constitutional design for a counter to government run amok, as
when the military and police use such firearms against their fellow
nationals. As the Tiananmen Square tragedy showed so
graphically, AK-47s fall into that category of weapons, and that is
why they are protected by the Second Amendment.

Twentieth-century military machines are far from invincible
when outflanked by armed citizen guerrillas. . .

Modern military machines are maintained by governments. There is no distinction

here among governments. Meanwhile, a proper AK-47 is a machine gun requiring a

federal permit.

The NRA's Executive Vice President Wayne LaPierre wrote in Guns, Crime and

Freedom (1994), p.7:

...those four words "The Right of the People" [from the
Declaration of Independence, a charter for revolution] state in

plain language that the people have the right, must have the right, to
use whatever means necessary, including force, to abolish
oppressive government.

natural right, a moral right, a God-given right, but it is not one of those "certain

unalienable rights"— not an individual civil right— that can possibly be secured by

government.

David Kopel, a prolific individual right advocate, wrote in "Trust the People: The

Case against Gun Control," Cato Institute Policy Analysis No. 109 (1988) explicitly

in the context of gun ownership:

The tools of political dissent should be privately owned and
unregistered.

The Second Amendment Foundation asserted in its amicus (Appendix E) in US v.

Francis J. Warin, 530 F.2d 104 (1976), and sought Second Amendment protection

for:

...a basic right of freemen to take up arms to defeat an oppressive
government.

Speaker of the US House of Representatives Newt Gingrich wrote in his book To Renew America (1994), p. 202:

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d. The Libertarian Fantasy: Hedging Consent.

to be armed outside of lawful authority than most can safely assert. A more

insidious hedge on the consent to be governed is the libertarian fantasy. The

individual right becomes a right to maintain a balance of power between a privately

armed populace and any and all government. The operating concept is individual

sovereignty. At best, it expresses a severe difficulty accommodating to public

authority, and the latent right to threaten revolution puts the individual in a tenuous

relationship with the state. "Individual sovereignty" and the "right to political

secession," applied even to individuals, are planks in the Libertarian Party Platform

(Appendix F). The concept of individual sovereignty reduces the Constitution to a

treaty, as per Hamilton supra, p. 6, among sovereign individuals who give no more

than their good faith. It is an expression of a demoralized public mood and a

defeatist retreat from political life:

Senator Ted Stevens of Alaska stated in the course of the Brady Law debates:

An armed citizenry, people who have the ability to defend themselves,
are [sic] not going to become an oppressed citizenry. Congressional
Record, November 19, 1993, p. S16315. (Appendix D)

No one has inquired into the Senator's meaning.

The District Court cites from Sanford Levinson's "The Embarrassing Second

Amendment" seven times. Levinson wrote (p. 651):

[O]ne aspect of the structure of checks and balances within the
purview of 18th century thought was the armed citizen. That is,
those who would limit the meaning of the Second Amendment to
the constitutional protection of state-controlled militias agree that
such protection rests on the perception that militarily competent
states were viewed as potential protection against a tyrannical
[federal] government....But this argument assumes that there are
only two basic components in the vertical structure of the American
polity national government and the states. [The words in added
italic that continue are quoted in full by the District Court.] It
ignores the implication that might be drawn from the Second,
Ninth and Tenth Amendments: that the citizenry itself can be
viewed as an important third component of republican governance
insofar as it stands ready to defend republican liberty against the
depredations of the other two structures, however futile that might
appear as a practical matter.

powers" to government, and give "a right to the Commonwealth to imploy" its

force? Or, did sovereign individuals make a treaty? Levinson references Sue

Wimmershoff-Caplan above with approval.

The District Court cites Stephen Halbrook, That Every Man be Armed, five times.

Halbrook argued Printz for the National Rifle Association before the Supreme

Court. Halbrook writes ( p. 8-9):

Conservatives," National Review, 1979 (Appendix G):

The individual would be fully sovereign in the libertarian
non-society and peace would be as precarious among individuals
as it is now is among the [state] powers.

society." Diplomacy is very polite, but, because sovereign states recognize no

higher law, when differences become irreconcilable and communication breaks

down, sovereign states go to war. Van den Haag, in the same article:

Institutions form a social order, ultimately articulated and defended
in essential respects by the state, through the monopoly of
legitimate coercive power exercised by its government. Any
particular coercion (law) of the state may well be contested. But
libertarians object not just to specific laws, but to legislation, to the
authority of the state, and to its coercive power per se. Libertarians
dissent from history and from the political institutions it has created
in all known civilization. For, although political institutions vary no
society has been able to do without them, as the libertarians
propose.

(Appendix H for source of monopoly on force).

amount of government in our lives and forms a continuum that spans from yahoos

holed up in a farmhouse on the prairie in defiance of all authority to the respectable

towers of legal academia. The subtitle to Stephen Newman's Liberalism at Wits'

End is The Libertarian Revolt against the Modern State. The scholarship the

District Court cites is ideological. The libertarian fantasy is a manifestation of the

libertarian revolt.

Just as the District Court exalts the militia into revolutionary and military

competence it did not have, the "legal scholars" find the meanings they seek.

The District Court cites from the legal scholarship James Madison's "the advantage of

being armed" from Federalist Paper No. 46, Patrick Henry's "That every man be

armed" from the Virginia ratification debates and Joseph Story's "the palladium of

the liberties of a republic" from his Commentaries on the Constitution (1833)

(expanded context in (Appendix I).

to law and government:

Besides the advantage of being armed, which the Americans possess
over the people of almost every other nation, the existence of
subordinate governments, to which the people are attached and by
which the militia officers are appointed... (Rossiter, p. 299)

The great object is, that every man be armed. But can the people
afford to pay for double sets of arms &c.? Every one who is able may
have a gun. (3 Elliot's Debates 387)

government in this context), the states or the federal government? So also are

Story's words lifted out of context. Story goes on to mention a "system of militia

discipline" and declares, "How it is practicable to keep the people duly armed

without some organization, it is difficult to see." Story's context was the citizen

soldier. The discipline and organization are imposed from above by law. The

militia was not self-constituted by individuals possessing a personal right.

...the concept of anonymity or privacy in gun ownership profoundly
departs from the conditions under which the Founders envisioned the
amendment operating. Under the militia laws (first colonial, then state
and eventually federal), every household, and/or male reaching the age
of majority, was required to maintain at least one firearm in good
condition. To prove compliance these firearms had to be submitted for
inspection periodically....

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II. THE DISTRICT COURT ERRED BY CONFUSING THE SECOND

AMENDMENT'S TRUE LEGACY, THE REPUBLICAN RIGHT TO BE

ARMED AS CITIZEN SOLDIERS, WITH A PERSONAL RIGHT TO

ARMS OUTSIDE OF THE RULE OF LAW.

Thomas Hobbes and Locke in the seventeenth century. (Halbrook has Hobbes and

Locke on opposite poles but they are in the same lineage.) All previous political

theory had been conservative: Individuals were born into political community with

obligations. In Christian Europe political authority and obligation were sanctioned

by scripture: St. Paul's injunction, "Obey the powers that be for they are of God." In

the Liberal tradition individuals are born with rights in the State of Nature. They

institute government to secure rights. In Hobbes and Locke (and the Declaration of

Independence) political authority derives from the consent of the governed not from

divine sanction. The simple replacement of popular sovereignty and consent for

divine right and arbitrary power involved England for much of a century in civil war

and revolution. The eighteenth century British Constitution which came out of those

struggles was a balance among the classical forms of government, monarchy,

aristocracy and democracy, manifest in the estates of the realm, the Crown, the

nobility (Lords), and the people (Commons). The rulers (the Crown) and the ruled

(the people) were separate estates of the realm.

had its roots in historical English practices and the republican ideologies that

emerged in the early modern period as the opposition ideologies to monarchy with

its magistrates and regular army. They emphasized the republican virtues of the

citizen soldier and the right of the citizen to participate in the military functions of

the state. The militia had some theoretical, but mostly rhetorical, significance under

the British Constitution. In The Creation of the American Republic (1969),

historian Gordon Wood describes the transformation from the concepts of the

British Constitution to the US Constitution, where, under representative self-

government, the rulers and the ruled become one and the same. Instead of making a

contract with the rulers, the people divided their sovereignty between state

government and the federal government. The Anti-Federalists insisted on the

Second Amendment because they projected their understanding of political concepts

from the British Constitution onto the US Constitution. In Anti-Federalist

consciousness, the states were the people, the ruled, analogous to the people in

Parliament; and the rulers, analogous to the monarchy and its magistrates, were the

Federal Government. The state constitutions of the Revolutionary period had strong

legislatures and weak governors. The Anti-Federalists identified the state

legislatures and state militias with the sovereignty of the people. It was that

sovereignty that they wanted to protect. (Rowland, dissertation, p. 394-5) They

wanted to preserve the constitutional balance that was present in the British

Constitution. However, the concepts had changed. The Second Amendment was an

anachronism when ratified. The libertarian fantasy has tried to resurrect the British

Constitution's balance between the people and the rulers and insert it into the anti-

state (Appendix F), anti-government ideologies and political cynicism of the present.

the 1830s. Colonial society was settled, deferential and hierarchical. After the

Revolution, American society expanded to fill a continent. It became more fluid and

mobile. (Cooper, p. 14) Not only did the conscript militia no longer serve a

theoretical purpose but it became impractical to enforce and maintain. Also, the

regular army of the United States did not, and has not, become, as the regular army

had in seventeenth century England, a feared instrument of political intrigue.

nation state. The United States, in its evolution into a modern state, for the first

time combined, in a national system, the citizen soldier of the conscript militia with

the professional soldier of the regular army in the Selective Service Act of 1917

which was challenged and held constitutional (Arver v. United States, 245 US 366

(1918); Goldman v. United States, 245 US 474 (1918), Ruthenberg v. United

States, 245 US 480 (1918)) (Friedman). Here is where we find the true legacy of

the Second Amendment. The theme of Russell Weigley's authoritative History of

the United States Army (1967) is the polarization from the beginning between

citizen soldiers and professional soldiers (p. 87):

The strong-government men had desired sufficient authority to create a
strong national army, and the Constitution fulfilled their wish. But in
the Constitution they retained the dual military system bequeathed to
the United States by its history: a citizen soldiery enrolled in the state
militias, plus a professional army of the type represented by the British
army or, more roughly, the Continental Army.

citizen soldiers and been proud of their condition and performance as such.

between a natural right to revolution and a civil right secured by government they

also maintain a great confusion between the right of the people to participate as

citizen soldiers and a personal right to be armed prior to political community,

without prior restraint or any state purpose.

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III. THE DISTRICT COURT ERRED IN CONFUSING A RIGHT TO

SELF-DEFENSE UNDER LAW AND GOVERNMENT WITH A RIGHT TO

SELF-DEFENSE OUTSIDE OF THE RULE OF LAW.

Court repeats. Self-defense is a right defined in law and protected by law, but it is

not an excuse to be armed outside of lawful authority. The self-defense security of

gun owners under law and government is to create legal categories of gun ownership

which gun owners as citizens, once they decide they are citizens, can effectively

apply against the lawless through legal means. There is no conflict in principle

between gun ownership for self-defense and prior restraint or accountability to

public authority. The self-defense sought in the personal right is self-defense in the

State of Nature which is the state of anarchy. There is no individual self-defense in

the state of anarchy. Van den Haag again:

In fact anarchy is actually impossible. The monopoly of legitimate
force held by the state can be replaced only by polyarchy which
cannot but be worse.

gun owners in the structure of a community, required training and imposed the duty

to guard against threats. It was a different concept in both theory and practice from

the personal right sought today. In eighteenth century consciousness, true liberty

was under law and opposed to both tyrannical rule and licentiousness (no law). (Rakove, p. 288-95).

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IV. THE DISTRICT COURT ERRED IN FRAMING THE ISSUES AS ONE

OF A CONFLICT BETWEEN A "COLLECTIVE" VERSUS

"INDIVIDUAL" RIGHT INTERPRETATION OF THE SECOND

AMENDMENT.

gun laws reasonable to US v. Miller, 307 US 174 (1939). The important phrase in

Miller which has been often repeated in subsequent cases is "reasonable relationship

to the preservation or efficiency of a well-regulated militia." This phrase implies

that militia is a function of lawful authority wherever and however constituted.

This is clear from militia clauses of eighteenth and nineteenth century state

constitutions. (Thorpe). The District Court finds the "crucial question" of an

"individual or collective right" unanswered in Miller. The Eighth Circuit, however,

in US v. Hale, 978 F.2d 1016 (1982) held that:

Whether Second Amendment "right to bear arms" for militia
purposes is "individual" or "collective" in nature is irrelevant where
individual's possession of arms is not related to preservation or
efficiency of militia, in which case there is no Second Amendment
protection.

in relation to that state function.

differentiated in struggling with gun laws: 1. Military law which has no relevance

here; 2. Militia law which was both military and civil depending on the

circumstance but is now archaic and only relevant as history to clarify the issue;

and, 3. Civil law which involves the legitimate police functions to regulated firearms

outside of any military or militia context. The key word for militia law is "required"

(Dist. Ct. Op., p. 9). Requirement presupposes possession. It is in this possession

that the personal right is sought, but, rather than a civil right, possession was a form

of tax— widely resisted— imposed by lawful authority. Militia law cannot be

resurrected as a protection for private individuals. The US Bankruptcy Court in

Brown (189 BR 653, Bkrtcy (1995)) indulged in a length discussion on the

difference between personal arms and military arms. The language of other courts is

clearly the language of civil regulation not militia law:

"reasonable regulation by the state under its police powers"
"the right subject to reasonable exercise of the police powers"
"the benefit to public safety"
Second Amendment Foundation v. City of Renton, 668 P. 2d 583 (1983).

"The states have always had great leeway in adopting summary
procedures to protect the public health and safety."
Rabbit v. Leonard et al., 413 A.2d 489 (1979)

"Reasonable regulation for the maintenance of public order"
US v. Francis J. Warin, 530 F.2d 104 (1976).

Printz that

If, however, the Second Amendment is read to confer a personal
right to "keep and bear arms," a colorable argument exists that the
Federal Government's regulatory scheme, at least as it pertains to
the purely intrastate sale and possession of firearms, runs afoul of
that Amendment's protections. (Dist. Ct. Op., p. 22)

governmental authority only outside of the reach of Federal authority; likewise, in

similarly confused words from Justice Scalia: "Of course, properly understood, it is

no limitation upon arms control by the states." ( Scalia, p. 137n) The personal right

does not seem to be eligible for Fourteenth Amendment protection against the states.

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V. POLITICAL CYNICISM

two extensively documented papers: Andrew Herz' "Gun Crazy" (1995) and Barnett

and Kates' "Under Fire" (1996). Herz' conventional arguments provoked

acrimonious condemnation from individual right advocates Barnett and Kates, but

Barnett and Kates arrive at this conclusion (p. 1259):

It may reasonably be argued that the Second Amendment does not
preclude such gun regulations as registration, licensing, background
checks, prohibition of arms to the deranged, children, and people with
felony or violence convictions.[540] What seems no longer open to
dispute is that the Amendment guarantees every law-abiding,
responsible adult a constitutional right to choose to possess arms.

What Barnett and Kates concede may "reasonably be argued" are essential

ingredients of firearms policy. There appears to be much common ground among

Barnett and Kates, many of the legal scholars they and the District Court cite, the

gun control organizations and even the gun manufacturers. The President of Colt

Manufacturing proposed a national permitting system in 1997 (Appendix J). Out of

this common ground could be distilled a reasonable and effective gun control policy

to address the current crisis in gun violence which the great majority of the people

could support and which would be consistent with sovereign public authority,

historical practice, the contours of citizenship under law and government and the

legitimate, as opposed to the anarchic or insurrectionist, interests of gun owners.

dismissing the insurrectionist accusations against Second Amendment rights as

"malicious straw man" (p. 1232), they take alarm at what they identify as the

confiscationist designs of the gun controllers. The personal right fabricated in the

volume of literature is a right secured against confiscation/prohibition. It is a right

that only has meaning in present gun control politics. They don't trust political

processes, want one foot planted in the State of Nature, and want it secured there by

the courts. The Second Amendment, however, is not relevant to the claim.

the case for the personal right does not hold up. Maintaining public order is a state

prerogative and confiscation in times of civil unrest or criminal activity is a

legitimate state action. However, a right to maintain a balance of power between an

armed populace and any and all government or a right to insurrection, to threaten or

fantasize insurrection has no purpose that a state can protect. Even the District

Court provides a quote from the eighteenth century that the right-to-arms does not

extend to those who have been or are in "actual rebellion" (p. 16).

of the gun lobby and libertarians is coercive government. The way we minimize

coercive government is to use free institution to get out all the relevant information,

conduct rational, informed public debate, arrive at and build public support around a

consensus, and let policy follow.

through this process. The completely necessary debate has not taken place. There

is no serious public enlightenment now and no political leadership on the substantive

political issues involved. Warin, the most important Second Amendment case since

Miller and before Emerson, has never been mentioned in the Washington Post.

Emerson, which involves the fundamental relationship between citizen and state,

was mentioned only once (AP report, 4/4/99, p. A 10, but not in all editions). (more

Washington Post in Appendix I) We hear much about trigger locks and there is

much effort and expense to collect public health statistics. There is no context that

includes the consent of the governed and the "just powers" of government.

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VI. CONCLUSION: SECURING NEW RIGHTS

knowledge, understanding and conviction. It is not the business of the courts to

conduct public debate or a national civics lesson on the contours of citizenship.

Until the confusion is cleared up in the public consciousness and the purposes of

gun ownership and regulation are defined in policy, the courts do not need to be

inventing new civil liberties to compensate for the failure in other places to debate

issues on their proper terms, reconcile differences, and enact and make work

reasonable policies which are consistent with history, a viable legal political order,

and what most players seem to be willing to accept. ACCORDINGLY, THE

JUDGMENT OF THE DISTRICT COURT SHOULD BE REVERSED.

Respectfully submitted,

__________________________________

Attorney for the Potowmack Institute, amicus curiae

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