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activities.” Heller, 554 U.S. at 574 (internal quotations omitted). After an extensive textual

analysis, the Court pronounced that, at its base, the Second Amendment “guarantee[s] the

individual right to possess and carry weapons in case of confrontation.” Id. at 592. This was

the first time the Court had found an individual right unrelated to militia service. The Court

grounded its ruling in the historical background of the Second Amendment, which has been
understood to codify a “pre-existing right.” Id. The Court acknowledged, however, that

Second Amendment rights were not unlimited and that its opinion should not be construed

as disturbing other longstanding prohibitions on firearm possession and use. Id. at 626-627.
The Court held that the District of Columbia law amounted to a complete prohibition on the

possession of certain firearms that extended to an individual’s home and would therefore

“fail constitutional muster.” Id. at 628-629.

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