title: Magnesium

text: Magnesium has three stable isotopes: , and . All are present in significant amounts in nature (see table of isotopes above). About 79% of Mg is . The isotope is radioactive and in the 1950s to 1970s was produced by several nuclear power plants for use in scientific experiments. This isotope has a relatively short half-life (21 hours) and its use was limited by shipping times.


title: Magnesium

text: The nuclide has found application in isotopic geology, similar to that of aluminium. is a radiogenic daughter product of , which has a half-life of 717,000 years. Excessive quantities of stable have been observed in the Ca-Al-rich inclusions of some carbonaceous chondrite meteorites. This anomalous abundance is attributed to the decay of its parent in the inclusions, and researchers conclude that such meteorites were formed in the solar nebula before the had decayed. These are among the oldest objects in the Solar System and contain preserved information about its early history.


title: Magnesium

text: It is conventional to plot / against an Al/Mg ratio. In an isochron dating plot, the Al/Mg ratio plotted is/. The slope of the isochron has no age significance, but indicates the initial / ratio in the sample at the time when the systems were separated from a common reservoir.


title: Magnesium

text: World production was approximately 1,100 kt in 2017, with the bulk being produced in China (930 kt) and Russia (60 kt). The United States was in the 20th century the major world supplier of this metal, supplying 45% of world production even as recently as 1995. Since the Chinese mastery of the Pidgeon process the US market share is at 7%, with a single US producer left: US Magnesium, a Renco Group company in Utah born from now-defunct Magcorp.


title: Magnesium

text: In September 2021, China took steps to reduce production of magnesium as a result of a government initiative to reduce energy availability for manufacturing industries, leading to a significant price increase.


title: Magnesium

text: China is almost completely reliant on the silicothermic Pidgeon process (the reduction of the oxide at high temperatures with silicon, often provided by a ferrosilicon alloy in which the iron is but a spectator in the reactions) to obtain the metal. The process can also be carried out with carbon at approx 2300 °C:


title: Magnesium

text: In the United States, magnesium is obtained principally with the Dow process, by electrolysis of fused magnesium chloride from brine and sea water. A saline solution containing ions is first treated with lime (calcium oxide) and the precipitated magnesium hydroxide is collected:


title: Magnesium

text: The hydroxide is then converted to a partial hydrate of magnesium chloride by treating the hydroxide with hydrochloric acid and heating of the product:


title: Magnesium

text: The salt is then electrolyzed in the molten state. At the cathode, the ion is reduced by two electrons to magnesium metal:


title: Magnesium

text: At the anode, each pair of ions is oxidized to chlorine gas, releasing two electrons to complete the circuit:


title: Magnesium

text: A new process, solid oxide membrane technology, involves the electrolytic reduction of MgO. At the cathode, ion is reduced by two electrons to magnesium metal. The electrolyte is yttria-stabilized zirconia (YSZ). The anode is a liquid metal. At the YSZ/liquid metal anode is oxidized. A layer of graphite borders the liquid metal anode, and at this interface carbon and oxygen react to form carbon monoxide. When silver is used as the liquid metal anode, there is no reductant carbon or hydrogen needed, and only oxygen gas is evolved at the anode. It has been reported that this method provides a 40% reduction in cost per pound over the electrolytic reduction method.


title: Magnesium

text: The name magnesium originates from the Greek word for locations related to the tribe of the Magnetes, either a district in Thessaly called Magnesia or Magnesia ad Sipylum, now in Turkey. It is related to magnetite and manganese, which also originated from this area, and required differentiation as separate substances. See manganese for this history.


title: Magnesium

text: In 1618, a farmer at Epsom in England attempted to give his cows water from a well there. The cows refused to drink because of the water's bitter taste, but the farmer noticed that the water seemed to heal scratches and rashes. The substance became known as Epsom salts and its fame spread. It was eventually recognized as hydrated magnesium sulfate, ·7.


title: Magnesium

text: The metal itself was first isolated by Sir Humphry Davy in England in 1808. He used electrolysis on a mixture of magnesia and mercuric oxide. Antoine Bussy prepared it in coherent form in 1831. Davy's first suggestion for a name was magnium, but the name magnesium is now used in English and all major European languages but Russian.


title: Magnesium

text: Magnesium is the third-most-commonly-used structural metal, following iron and aluminium. The main applications of magnesium are, in order: aluminium alloys, die-casting (alloyed with zinc), removing sulfur in the production of iron and steel, and the production of titanium in the Kroll process.


title: Magnesium

text: Magnesium is used in lightweight materials and alloys. For example, when infused with silicon carbide nanoparticles, it has extremely high specific strength.


title: Magnesium

text: Historically, magnesium was one of the main aerospace construction metals and was used for German military aircraft as early as World War I and extensively for German aircraft in World War II. The Germans coined the name "Elektron" for magnesium alloy, a term which is still used today. In the commercial aerospace industry, magnesium was generally restricted to engine-related components, due to fire and corrosion hazards. Magnesium alloy use in aerospace is increasing in the 21st century, driven by the importance of fuel economy. Recent developments in metallurgy and manufacturing have allowed for the potential for magnesium alloys to act as replacements for aluminium and steel alloys in certain applications.


title: Magnesium

text: In the form of thin ribbons, magnesium is used to purify solvents; for example, preparing super-dry ethanol.


title: Magnesium

text: Both AJ62A and AE44 are recent developments in high-temperature low-creep magnesium alloys. The general strategy for such alloys is to form intermetallic precipitates at the grain boundaries, for example by adding mischmetal or calcium. New alloy development and lower costs that make magnesium competitive with aluminium will increase the number of automotive applications.


title: Magnesium

text: Because of low density and good mechanical and electrical properties, magnesium is used for manufacturing of mobile phones, laptop and tablet computers, cameras, and other electronic components. It was used as a premium feature because of its light weight in some 2020 laptops.


title: Magnesium

text: Magnesium metal and its alloys can be explosive hazards; they are highly flammable in their pure form when molten or in powder or ribbon form. Burning or molten magnesium reacts violently with water. When working with powdered magnesium, safety glasses with eye protection and UV filters (such as welders use) are employed because burning magnesium produces ultraviolet light that can permanently damage the retina of a human eye.


title: Magnesium

text: Therefore, water cannot extinguish magnesium fires. The hydrogen gas produced intensifies the fire. Dry sand is an effective smothering agent, but only on relatively level and flat surfaces.


title: Magnesium

text: Burning magnesium can be quenched by using a Class D dry chemical fire extinguisher, or by covering the fire with sand or magnesium foundry flux to remove its air source.


title: Magnesium

text: Magnesium compounds, primarily magnesium oxide (MgO), are used as a refractory material in furnace linings for producing iron, steel, nonferrous metals, glass, and cement. Magnesium oxide and other magnesium compounds are also used in the agricultural, chemical, and construction industries. Magnesium oxide from calcination is used as an electrical insulator in fire-resistant cables.


title: Magnesium

text: Magnesium reacted with an alkyl halide gives a Grignard reagent, which is a very useful tool for preparing alcohols.


title: Magnesium

text: Magnesium salts are included in various foods, fertilizers (magnesium is a component of chlorophyll), and microbe culture media.


title: Magnesium

text: The important interaction between phosphate and magnesium ions makes magnesium essential to the basic nucleic acid chemistry of all cells of all known living organisms. More than 300 enzymes require magnesium ions for their catalytic action, including all enzymes using or synthesizing ATP and those that use other nucleotides to synthesize DNA and RNA. The ATP molecule is normally found in a chelate with a magnesium ion.


title: Magnesium

text: Spices, nuts, cereals, cocoa and vegetables are rich sources of magnesium. Green leafy vegetables such as spinach are also rich in magnesium.


title: Magnesium

text: In the UK, the recommended daily values for magnesium are 300 mg for men and 270 mg for women. In the U.S. the Recommended Dietary Allowances (RDAs) are 400 mg for men ages 19–30 and 420 mg for older; for women 310 mg for ages 19–30 and 320 mg for older.


title: Magnesium

text: Numerous pharmaceutical preparations of magnesium and dietary supplements are available. In two human trials magnesium oxide, one of the most common forms in magnesium dietary supplements because of its high magnesium content per weight, was less bioavailable than magnesium citrate, chloride, lactate or aspartate.


title: Magnesium

text: An adult body has 22–26 grams of magnesium, with 60% in the skeleton, 39% intracellular (20% in skeletal muscle), and 1% extracellular. Serum levels are typically 0.7–1.0 mmol/L or 1.8–2.4 mEq/L. Serum magnesium levels may be normal even when intracellular magnesium is deficient. The mechanisms for maintaining the magnesium level in the serum are varying gastrointestinal absorption and renal excretion. Intracellular magnesium is correlated with intracellular potassium. Increased magnesium lowers calcium and can either prevent hypercalcemia or cause hypocalcemia depending on the initial level. Both low and high protein intake conditions inhibit magnesium absorption, as does the amount of phosphate, phytate, and fat in the gut. Unabsorbed dietary magnesium is excreted in feces; absorbed magnesium is excreted in urine and sweat.


title: Magnesium

text: Magnesium status may be assessed by measuring serum and erythrocyte magnesium concentrations coupled with urinary and fecal magnesium content, but intravenous magnesium loading tests are more accurate and practical. A retention of 20% or more of the injected amount indicates deficiency. As of 2004, no biomarker has been established for magnesium.


title: Magnesium

text: Magnesium concentrations in plasma or serum may be monitored for efficacy and safety in those receiving the drug therapeutically, to confirm the diagnosis in potential poisoning victims, or to assist in the forensic investigation in a case of fatal overdose. The newborn children of mothers who received parenteral magnesium sulfate during labor may exhibit toxicity with normal serum magnesium levels.


title: Magnesium

text: Low plasma magnesium (hypomagnesemia) is common: it is found in 2.5–15% of the general population. From 2005 to 2006, 48 percent of the United States population consumed less magnesium than recommended in the Dietary Reference Intake. Other causes are increased renal or gastrointestinal loss, an increased intracellular shift, and proton-pump inhibitor antacid therapy. Most are asymptomatic, but symptoms referable to neuromuscular, cardiovascular, and metabolic dysfunction may occur. Alcoholism is often associated with magnesium deficiency. Chronically low serum magnesium levels are associated with metabolic syndrome, diabetes mellitus type 2, fasciculation, and hypertension.


title: Magnesium

text: Overdose from dietary sources alone is unlikely because excess magnesium in the blood is promptly filtered by the kidneys, and overdose is more likely in the presence of impaired renal function. In spite of this, megadose therapy has caused death in a young child, and severe hypermagnesemia in a woman and a young girl who had healthy kidneys.


title: Magnesium

text: The most common symptoms of overdose are nausea, vomiting, and diarrhea; other symptoms include hypotension, confusion, slowed heart and respiratory rates, deficiencies of other minerals, coma, cardiac arrhythmia, and death from cardiac arrest.


title: Magnesium

text: Plants require magnesium to synthesize chlorophyll, essential for photosynthesis. Magnesium in the center of the porphyrin ring in chlorophyll functions in a manner similar to the iron in the center of the porphyrin ring in heme. Magnesium deficiency in plants causes late-season yellowing between leaf veins, especially in older leaves, and can be corrected by either applying epsom salts (which is rapidly leached), or crushed dolomitic limestone, to the soil.


title: Ralph Lauren

text: Ralph Lauren, ( ; ; born October 14, 1939) is an American fashion designer, philanthropist, and billionaire businessman, best known for the Ralph Lauren Corporation, a global multibillion-dollar enterprise. He has become well known for his collection of rare automobiles, some of which have been displayed in museum exhibits. Lauren stepped down as CEO of the company in September 2015 but remains executive chairman and chief creative officer. As of April 2022, his net worth was estimated at US$6.9 billion.


title: Ralph Lauren

text: Ralph Lifshitz was born on October 14, 1939, in the Bronx, New York City, to Ashkenazi Jewish immigrants, Frieda (Cutler) and Frank Lifshitz, an artist and house painter, from Pinsk, Second Polish Republic, now Belarus. The youngest of four siblings, he has two brothers and one sister.


title: Ralph Lauren

text: Lauren attended day school followed by the Manhattan Talmudical Academy, before eventually graduating from DeWitt Clinton High School in 1957. He went to Baruch College of the City University of New York (CUNY), where he studied business, although he dropped out after two years.


title: Ralph Lauren

text: Lauren was one of several design leaders raised in the Jewish community in the Bronx, along with Calvin Klein and Robert Denning.


title: Ralph Lauren

text: From 1962 to 1964 Lauren served in the United States Army. After his discharge, he worked briefly for Brooks Brothers as a sales assistant before becoming a salesman for Rivetz, a necktie company. At age 28, working for tie manufacturer Beau Brummell, Lauren convinced the company president to let him start his own line. He launched The Ralph Lauren Corporation in 1967 with men's ties.


title: Ralph Lauren

text: Drawing on his interests in sports, Lauren named his first full line of menswear 'Polo' in 1968. He worked out of a single "drawer" from a showroom in the Empire State Building and made deliveries to stores himself. By 1969, the Manhattan department store Bloomingdale's sold Lauren's men’s line exclusively. It was the first time that Bloomingdale's had given a designer their own in-store boutique.


title: Ralph Lauren

text: In 1972, the Ralph Lauren Corporation introduced a signature cotton mesh Polo shirt in various colors. Featuring the polo player logo at the chest, the shirt became emblematic of the preppy look—one of Ralph Lauren's signature styles. The tagline for the ad campaign was: "Every team has its color – Polo has seventeen."


title: Ralph Lauren

text: In 1974, he outfitted the male cast of The Great Gatsby in costumes from his Polo line – a 1920s-style series of men's suits and sweaters, except for the pink suit which Lauren designed especially for Robert Redford's Jay Gatsby. In 1977, Diane Keaton and Woody Allen wore Lauren's clothes throughout their Oscar-winning film, Annie Hall.


title: Ralph Lauren

text: The first Ralph Lauren fragrances, produced by Warner-Lauren, Ltd. were launched at Bloomingdale's in March 1978. Lauren, a fragrance for women, on March 12 and Polo, cologne for men, on March 26. This was the first time that a designer had introduced two fragrances – one for men and one for women – simultaneously. The company entered the European market, and went international in 1981 with the opening of the first freestanding store for an American designer on New Bond Street in the West End of London, England.


title: Ralph Lauren

text: Ralph Lauren opened his first flagship in the Rhinelander mansion, on Madison Avenue and 72nd Street in New York City in 1986. Lauren re-created the building's original opulence with a young design consultant named Naomi Leff, with whom he had previously worked on Ralph Lauren Home. The Polo Sport line was introduced in 1992 followed by over ten additional lines and acquired brands, including Ralph Lauren Purple Label in 1995 and Lauren Ralph Lauren in 1996.


title: Ralph Lauren

text: The 98-seat restaurant RL opened in March 1999 in Chicago in a newly constructed building adjacent to the largest Ralph Lauren store at the corner of Chicago and Michigan Avenues. It was followed by the opening of two additional restaurants – Ralph's at 173 Boulevard Saint Germain Paris flagship store in 2010 and The Polo Bar at Polo's flagship in New York in 2015.


title: Ralph Lauren

text: The company launched its website and online shop in 2000 as polo.com by RL Media (a cooperation between Ralph Lauren and NBC). In 2007, Ralph Lauren Corporation acquired the NBC share of RL Media and the web site was relaunched as ralphlauren.com. In 2008, Ralph Lauren Corporation launched a brand called American Living, exclusively for JCPenney. It was the largest cross-category brand launch in the history of Ralph Lauren and JCPenney. On September 29, 2015, it was announced that Stefan Larsson would replace the company's founder, Ralph Lauren, as CEO in November. Lauren will stay on as executive chairman and chief creative officer.


title: Ralph Lauren

text: Lauren has appeared on over 100 magazine covers including "Architectural Digest", "GQ", "Forbes", "Town & Country", "TIME" and "Vogue".


title: Ralph Lauren

text: Lauren celebrated the 50th anniversary of his brand in a fashion show at Bethesda Terrace in Central Park on September 8, 2018. Attendees included Oprah Winfrey, Hillary Clinton, Kanye West, Robert DeNiro, and Jessica Chastain.


title: Ralph Lauren

text: On December 20, 1964, Lauren married Ricky Ann Loew-Beer in New York City. She is the daughter of Margaret Vytouch and Rudolph Loew-Beer. The two had met six months earlier, in a doctor's office where she was working as a receptionist and on alternate days teaching dance. She is the author of "".


title: Ralph Lauren

text: They have three children. Andrew Lauren (b. 1969) is a film producer and actor. David Lauren (b. 1971) is executive vice president of Global Advertising, Marketing, and Communications at Ralph Lauren Corporation and Dylan Lauren (b. 1974). In September 2011, David married Lauren Bush, the granddaughter of former U.S. President George H. W. Bush. Lauren and David have two children and live in Manhattan. Dylan Lauren, owner of Dylan's Candy Bar in New York City, was married in June 2011 to hedge fund manager Paul Arrouet. Dylan and Paul welcomed twins on April 13, 2015 via surrogate in New York City.


title: Ralph Lauren

text: In April 1987, Ralph Lauren underwent surgery to remove a benign brain tumor and made a full recovery.


title: Ralph Lauren

text: Lauren owns a 17,000-acre cattle ranch in Ridgway, Colorado, and a 17,000 sq foot manor built in 1919 in Bedford, New York.


title: Ralph Lauren

text: Ralph Lauren is well known as a collector of automobiles, with about 100 automobiles, some being extremely rare. He owns a 1962 Ferrari 250 GTO, two Ferrari TRs, three 1996 McLaren F1s (one of them an ultra-rare McLaren F1 LM), a Mercedes-Benz 300 SL Gullwing, a 1929 Bentley 4½ Litre ("Blower Bentley"), one Bugatti Type 57SC Atlantic, a 1937 Bugatti Type 57SC Gangloff, a Porsche 911 GT3 RS, a Bugatti Veyron, a 1930 Mercedes-Benz SSK "Count Trossi" (aka "The Black Prince"), a 1938 Alfa Romeo 8C 2900B Mille Miglia. and a rare Lamborghini Reventón Roadster.


title: Ralph Lauren

text: His cars have won "Best of Show" at the Pebble Beach Concours d'Elegance twice, his 1938 Bugatti Type 57SC Atlantic won in 1990 and his 1930 Mercedes-Benz SSK "Count Trossi" roadster won in 1993. In 2005 his collection was displayed at Boston's Museum of Fine Arts. Seventeen cars from his collection were exhibited at the Musée des Arts Décoratifs, Paris, in 2011. In 2017, Lauren's now $600 million dollar car collection took center stage during New York Fashion Week.


title: Ralph Lauren

text: Lauren stated in May 2014, "I hate when people call me philanthropic because I see it as more coming from the heart."


title: Ralph Lauren

text: In 1989 Lauren co-founded the Nina Hyde Center for Breast Cancer Research at Georgetown University Hospital in Washington D.C. in memory of the late "Post" fashion correspondent. He served as chairman and created the name and symbol for Fashion Targets Breast Cancer, a charitable initiative of the CFDA that founded in 1994 that marshals the goodwill and services of the fashion industry to raise public awareness and funds for breast cancer internationally.


title: Ralph Lauren

text: In 2000 the Ralph Lauren Corporation launched its Volunteer Program, which energizes employees and creates meaningful connections with the communities in which they work. On Friday, September 15, Ralph Lauren Corporation launched the Pink Pony Campaign, a national initiative to reduce disparities in cancer care by raising awareness as well as enhancing prevention, screening, and treatment in poor and underserved communities.


title: Ralph Lauren

text: The Polo Ralph Lauren Foundation established the American Heroes Fund following the September 11th attacks to allow Polo's 10,000 employees worldwide, as well as their customers, the opportunity to participate in the relief effort.


title: Ralph Lauren

text: In 2003, Lauren supported the establishment the Ralph Lauren Center for Cancer Care and Prevention in Harlem. The Center is a collaboration between Ralph Lauren, Memorial Sloan-Kettering, and North General Hospital in Harlem, New York City.


title: Ralph Lauren

text: The Polo Fashion School was established in 2004, in which Company executives work with inner-city youth to offer insights into the fashion business. Established in 2006, the Polo Jeans G.I.V.E. (Get Involved, Volunteer, Exceed) campaign was created to inspire and encourage community service through volunteerism by supporting the efforts of dedicated volunteers and their causes.


title: Ralph Lauren

text: The Star-Spangled Banner, the original 1813 flag that inspired Francis Scott Key to write the United States National Anthem, was preserved by a $10 million contribution to Save America's Treasures from Polo Ralph Lauren in 1998. The flag was then unveiled on Wednesday, November 19, 2008, in a new gallery at the Smithsonian National Museum of American History, in Washington, D.C.


title: Ralph Lauren

text: Ralph Lauren Corporation announced in July 2013 its commitment to restore the elite École des Beaux-Arts in Paris, one of the most influential art schools in France.


title: Ralph Lauren

text: In 2014, the Ralph Lauren Corporation partnered with the Royal Marsden, the largest and most comprehensive cancer center in Europe, to develop a world-class breast cancer research facility. They opened the Royal Marsden Ralph Lauren Center for Breast Cancer Research in 2016.


title: Dark Ages (historiography)

text: The Dark Ages is a term for the Early Middle Ages, or occasionally the entire Middle Ages, in Western Europe after the fall of the Western Roman Empire that characterises it as marked by economic, intellectual and cultural decline.


title: Dark Ages (historiography)

text: The concept of a "Dark Age" originated in the 1330s with the Italian scholar Petrarch, who regarded the post-Roman centuries as "dark" compared to the "light" of classical antiquity. The term employs traditional light-versus-darkness imagery to contrast the era's "darkness" (ignorance and error) with earlier and later periods of "light" (knowledge and understanding). The phrase "Dark Age" itself derives from the Latin "saeculum obscurum", originally applied by Caesar Baronius in 1602 when he referred to a tumultuous period in the 10th and 11th centuries. The concept thus came to characterize the entire Middle Ages as a time of intellectual darkness in Europe between the fall of Rome and the Renaissance that became especially popular during the 18th-century Age of Enlightenment. Others, however, have used the term to denote the relative ignorance of historians regarding at least the early part of the Middle Ages, from a scarcity of records.


title: Dark Ages (historiography)

text: As the accomplishments of the era came to be better understood in the 19th and the 20th centuries, scholars began restricting the "Dark Ages" appellation to the Early Middle Ages (), and today's scholars also reject its usage for the period. The majority of modern scholars avoid the term altogether due to its negative connotations, finding it misleading and inaccurate. Petrarch's pejorative meaning remains in use, typically in popular culture, which often simplistically views the Middle Ages as a time of violence and backwardness.


title: Dark Ages (historiography)

text: The idea of a Dark Age originated with the Tuscan scholar Petrarch in the 1330s. Writing of the past, he said: "Amidst the errors there shone forth men of genius; no less keen were their eyes, although they were "surrounded by darkness" and dense gloom". Christian writers, including Petrarch himself, had long used traditional metaphors of 'light versus darkness' to describe 'good versus evil'. Petrarch was the first to give the metaphor secular meaning by reversing its application. He now saw classical antiquity, so long considered a 'dark' age for its lack of Christianity, in the 'light' of its cultural achievements, while Petrarch's own time, allegedly lacking such cultural achievements, was seen as the age of darkness.


title: Dark Ages (historiography)

text: From his perspective on the Italian peninsula, Petrarch saw the Roman period and classical antiquity as an expression of greatness. He spent much of his time traveling through Europe, rediscovering and republishing classic Latin and Greek texts. He wanted to restore the Latin language to its former purity. Renaissance humanists saw the preceding 900 years as a time of stagnation, with history unfolding not along the religious outline of Saint Augustine's Six Ages of the World, but in "cultural" (or secular) terms through progressive development of classical ideals, literature, and art.


title: Dark Ages (historiography)

text: Petrarch wrote that history had two periods: the classic period of Greeks and Romans, followed by a time of darkness in which he saw himself living. In around 1343, in the conclusion of his epic "Africa", he wrote: "My fate is to live among varied and confusing storms. But for you perhaps, if as I hope and wish you will live long after me, there will follow a better age. This sleep of forgetfulness will not last forever. When the darkness has been dispersed, our descendants can come again in the former pure radiance." In the 15th century, historians Leonardo Bruni and Flavio Biondo developed a three-tier outline of history. They used Petrarch's two ages, plus a modern, 'better age', which they believed the world had entered. Later the term 'Middle Ages' – Latin "media tempestas" (1469) or "medium aevum" (1604) – was used to describe the period of supposed decline.


title: Dark Ages (historiography)

text: During the Reformations of the 16th and 17th centuries, Protestants generally had a similar view to Renaissance humanists such as Petrarch, but also added an anti-Catholic perspective. They saw classical antiquity as a golden time, not only because of its Latin literature, but also because it witnessed the beginnings of Christianity. They promoted the idea that the 'Middle Age' was a time of darkness also because of corruption within the Catholic Church, such as: popes ruling as kings, veneration of saints' relics, a licentious priesthood, and institutionalized moral hypocrisy.


title: Dark Ages (historiography)

text: In response to the Protestants, Catholics developed a counter-image to depict the High Middle Ages in particular as a period of social and religious harmony, and not 'dark' at all. The most important Catholic reply to the "Magdeburg Centuries" was the "Annales Ecclesiastici" by Cardinal Caesar Baronius. Baronius was a trained historian who produced a work that the "Encyclopædia Britannica" in 1911 described as "far surpassing anything before" and that Acton regarded as "the greatest history of the Church ever written". The "Annales" covered the first twelve centuries of Christianity to 1198, and was published in twelve volumes between 1588 and 1607. It was in Volume X that Baronius coined the term "dark age" for the period between the end of the Carolingian Empire in 888 and the first stirrings of Gregorian Reform under Pope Clement II in 1046:


title: Dark Ages (historiography)

text: Significantly, Baronius termed the age 'dark' because of the paucity of written records. The "lack of writers" he referred to may be illustrated by comparing the number of volumes in Migne's "Patrologia Latina" containing the work of Latin writers from the 10th century (the heart of the age he called 'dark') with the number containing the work of writers from the preceding and succeeding centuries. A minority of these writers were historians.


title: Dark Ages (historiography)

text: There is a sharp drop from 34 volumes in the 9th century to just 8 in the 10th. The 11th century, with 13, evidences a certain recovery, and the 12th century, with 40, surpasses the 9th, something the 13th, with just 26, fails to do. There was indeed a 'dark age', in Baronius's sense of a "lack of writers", between the Carolingian Renaissance in the 9th century and the beginnings, some time in the 11th, of what has been called the Renaissance of the 12th century. Furthermore, there was an earlier period of "lack of writers" during the 7th and 8th centuries. So, in Western Europe, two 'dark ages' can be identified, separated by the brilliant but brief Carolingian Renaissance.


title: Dark Ages (historiography)

text: Baronius' 'dark age' seems to have struck historians, for it was in the 17th century that the term started to spread to various European languages, with his original Latin term "" being reserved for the period he had applied it to. But while some, following Baronius, used 'dark age' neutrally to refer to a dearth of written records, others used it pejoratively, lapsing into that lack of objectivity that has discredited the term for many modern historians.


title: Dark Ages (historiography)

text: The first British historian to use the term was most likely Gilbert Burnet, in the form 'darker ages' which appears several times in his work during the later 17th century. The earliest reference seems to be in the "Epistle Dedicatory" to Volume I of "The History of the Reformation of the Church of England" of 1679, where he writes: "The design of the reformation was to restore Christianity to what it was at first, and to purge it of those corruptions, with which it was overrun in the later and darker ages." He uses it again in the 1682 Volume II, where he dismisses the story of "St George's fighting with the dragon" as "a legend formed in the darker ages to support the humour of chivalry". Burnet was a bishop chronicling how England became Protestant, and his use of the term is invariably pejorative.


title: Dark Ages (historiography)

text: During the Age of Enlightenment of the 17th and 18th centuries, many critical thinkers saw religion as antithetical to reason. For them the Middle Ages, or "Age of Faith", was therefore the opposite of the Age of Reason. Baruch Spinoza, Bernard Fontenelle, Immanuel Kant, David Hume, Thomas Jefferson, Thomas Paine, Denis Diderot,


title: Dark Ages (historiography)

text: Voltaire, Marquis De Sade and Jean-Jacques Rousseau were vocal in attacking the Middle Ages as a period of social regress dominated by religion, while Gibbon in "The History of the Decline and Fall of the Roman Empire" expressed contempt for the "rubbish of the Dark Ages". Yet just as Petrarch, seeing himself at the cusp of a "new age", was criticising the centuries before his own time, so too were Enlightenment writers.


title: Dark Ages (historiography)

text: Consequently, an evolution had occurred in at least three ways. Petrarch's original metaphor of light versus dark has expanded over time, implicitly at least. Even if later humanists no longer saw themselves living in a "dark" age, their times were still not "light" enough for 18th-century writers who saw themselves as living in the "real" Age of Enlightenment, while the period to be condemned stretched to include what we now call Early Modern times. Additionally, Petrarch's metaphor of darkness, which he used mainly to deplore what he saw as a lack of secular achievement, was sharpened to take on a more explicitly anti-religious and anti-clerical meaning.


title: Dark Ages (historiography)

text: In the late 18th and early 19th centuries, the Romantics reversed the negative assessment of Enlightenment critics with a vogue for medievalism. The word "Gothic" had been a term of opprobrium akin to "Vandal" until a few self-confident mid-18th-century English "Goths" like Horace Walpole initiated the Gothic Revival in the arts. This stimulated interest in the Middle Ages, which for the following generation began to take on the idyllic image of an "Age of Faith". This, reacting to a world dominated by Enlightenment rationalism, expressed a romantic view of a Golden Age of chivalry. The Middle Ages were seen with nostalgia as a period of social and environmental harmony and spiritual inspiration, in contrast to the excesses of the French Revolution and, most of all, to the environmental and social upheavals and utilitarianism of the developing Industrial Revolution. The Romantics' view is still represented in modern-day fairs and festivals celebrating the period with 'merrie' costumes and events.


title: Dark Ages (historiography)

text: Just as Petrarch had twisted the meaning of light versus darkness, so the Romantics had twisted the judgment of the Enlightenment. However, the period they idealized was largely the High Middle Ages, extending into Early Modern times. In one respect, this negated the religious aspect of Petrarch's judgment, since these later centuries were those when the power and prestige of the Church were at their height. To many, the scope of the Dark Ages was becoming divorced from this period, denoting mainly the centuries immediately following the fall of Rome.


title: Dark Ages (historiography)

text: The term was widely used by 19th-century historians. In 1860, in "The Civilization of the Renaissance in Italy", Jacob Burckhardt delineated the contrast between the medieval 'dark ages' and the more enlightened Renaissance, which had revived the cultural and intellectual achievements of antiquity. The earliest entry for a capitalized "Dark Ages" in the "Oxford English Dictionary" (OED) is a reference in Henry Thomas Buckle's "History of Civilization in England" in 1857, who wrote: "During these, which are rightly called the Dark Ages, the clergy were supreme." The OED in 1894 defined an uncapitalised "dark ages" as "a term sometimes applied to the period of the Middle Ages to mark the intellectual darkness characteristic of the time".


title: Dark Ages (historiography)

text: However, the early 20th century saw a radical re-evaluation of the Middle Ages, which called into question the terminology of darkness, or at least its more pejorative use. In 1977, the historian Denys Hay spoke ironically of "the lively centuries which we call dark". More forcefully, a book about the history of German literature published in 2007 describes "the dark ages" as "a popular if uninformed manner of speaking".


title: Dark Ages (historiography)

text: Most modern historians do not use the term "dark ages", preferring terms such as Early Middle Ages. But when used by some historians today, the term "Dark Ages" is meant to describe the economic, political, and cultural problems of the era. For others, the term Dark Ages is intended to be neutral, expressing the idea that the events of the period seem 'dark' to us because of the paucity of the historical record. For example, Robert Sallares, commenting on the lack of sources to establish whether the plague pandemic of 541 to 750 reached northern Europe, opines "the epithet "Dark Ages" is surely still an appropriate description of this period". The term is also used in this sense (often in the singular) to reference the Bronze Age collapse and the subsequent Greek Dark Ages, the brief Parthian Dark Age (1st century BC), the dark ages of Cambodia (c. 1450–1863 AD), and also a hypothetical Digital Dark Age which would ensue if the electronic documents produced in the current period were to become unreadable at some point in the future. Some Byzantinists have used the term Byzantine Dark Ages to refer to the period from the earliest Muslim conquests to about 800, because there are no extant historical texts in Greek from this period, and thus the history of the Byzantine Empire and its territories that were conquered by the Muslims is poorly understood and must be reconstructed from other contemporaneous sources, such as religious texts. The term "dark age" is not restricted to the discipline of history. Since the archaeological evidence for some periods is abundant and for others scanty, there are also archaeological dark ages.


title: Dark Ages (historiography)

text: Since the Late Middle Ages significantly overlap with the Renaissance, the term 'Dark Ages' became restricted to distinct times and places in medieval Europe. Thus the 5th and 6th centuries in Britain, at the height of the Saxon invasions, have been called "the darkest of the Dark Ages", in view of the societal collapse of the period and the consequent lack of historical records. Further south and east, the same was true in the former Roman province of Dacia, where history after the Roman withdrawal went unrecorded for centuries as Slavs, Avars, Bulgars, and others struggled for supremacy in the Danube basin, and events there are still disputed. However, at this time the Abbasid Caliphate is often considered to have experienced its Golden Age rather than Dark Age; consequently, usage of the term must also specify a geography. While Petrarch's concept of a Dark Age corresponded to a mostly Christian period following pre-Christian Rome, today the term mainly applies to the cultures and periods in Europe that were least Christianized, and thus most sparsely covered by chronicles and other contemporary sources, at the time mostly written by Catholic clergy.


title: Dark Ages (historiography)

text: However, from the later 20th century onward, other historians became critical even of this nonjudgmental use of the term, for two main reasons. Firstly, it is questionable whether it is ever possible to use the term in a neutral way: scholars may intend this, but ordinary readers may not understand it so. Secondly, 20th-century scholarship had increased understanding of the history and culture of the period, to such an extent that it is no longer really 'dark' to us. To avoid the value judgment implied by the expression, many historians now avoid it altogether. It was occasionally used up to the 1990s by historians of early medieval Britain, for example in the title of the 1991 book by Ann Williams, Alfred Smyth and D. P. Kirby, "A Biographical Dictionary of Dark Age Britain, England, Scotland and Wales, c.500-c.1050", and in the comment by Richard Abels in 1998 that the greatness of Alfred the Great "was the greatness of a Dark Age king". In 2020, John Blair, Stephen Rippon and Christopher Smart observed that: "The days when archaeologists and historians referred to the fifth to the tenth centuries as the 'Dark Ages' are long gone, and the material culture produced during that period demonstrates a high degree of sophistication."


title: Dark Ages (historiography)

text: A 2021 lecture by Howard Williams of Chester University explored how "stereotypes and popular perceptions of the Early Middle Ages – popularly still considered the European 'Dark Ages' – plague popular culture"; and finding 'Dark Ages' is "rife outside of academic literature, including in newspaper articles and media debates." As to why it is used, according to Williams, legends and racial misunderstandings have been revitalized by modern nationalists, colonialists and imperialists around present-day concepts of identity, faith and origin myths i.e. appropriating historical myths for modern political ends.


title: Dark Ages (historiography)

text: In a book about medievalisms in popular culture by Andrew B. R. Elliott (2017), he found "by far" the most common use of 'Dark Ages' is to "signify a general sense of backwardness or lack of technological sophistication", in particular noting how it has become entrenched in daily and political discourse. Reasons for use, according to Elliott, are often "banal medievalisms", which are "characterized mainly by being unconscious, unwitting and by having little or no intention to refer to the Middle Ages"; for example, referring to an insurance industry that still relied on paper instead of computers as being in the 'Dark Ages'. These banal uses are little more than tropes that inherently contain a criticism about lack of progress. Elliott connects 'Dark Ages' to the "Myth of Progress", also observed by Joseph Tainter, who says, "There is genuine bias against so-called 'Dark Ages'" because of a modern belief that society normally traverses from lesser to greater complexity, and when complexity is reduced during a collapse, this is perceived as out of the ordinary and thus undesirable; he counters that complexity is rare in human history, a costly mode of organization that must be constantly maintained, and periods of less complexity are common and to be expected as part of the overall progression towards greater complexity.


title: Dark Ages (historiography)

text: In Peter S. Wells's 2008 book, "Barbarians to Angels: The Dark Ages Reconsidered", he writes "I have tried to show that far from being a period of cultural bleakness and unmitigated violence, the centuries (5th - 9th) known popularly as the Dark Ages were a time of dynamic development, cultural creativity, and long-distance networking". He writes that our "popular understanding" of these centuries, "depends largely on the picture of barbarian invaders that Edward Gibbon presented more than two hundred years ago," and that this view has been accepted "by many who have read and admire Gibbon's work."


title: Dark Ages (historiography)

text: David C. Lindberg, a science and religion historian, says the 'Dark Ages' are "according to wide-spread popular belief" portrayed as "a time of ignorance, barbarism and superstition", for which he asserts "blame is most often laid at the feet of the Christian church". Medieval historian Matthew Gabriele echoes this view as a myth of popular culture. Andrew B. R. Elliott notes the extent to which "Middle Ages/Dark Ages have come to be synonymous with religious persecution, witch hunts and scientific ignorance".


title: Second Amendment to the United States Constitution

text: The Second Amendment (Amendment II) to the United States Constitution protects the right to keep and bear arms. It was ratified on December 15, 1791, along with nine other articles of the Bill of Rights. In "District of Columbia v. Heller" (2008), the Supreme Court affirmed for the first time that the right belongs to individuals, for self-defense in the home, while also including, as "dicta", that the right is not unlimited and does not preclude the existence of certain long-standing prohibitions such as those forbidding "the possession of firearms by felons and the mentally ill" or restrictions on "the carrying of dangerous and unusual weapons". In "McDonald v. City of Chicago" (2010) the Supreme Court ruled that state and local governments are limited to the same extent as the federal government from infringing upon this right. "New York State Rifle & Pistol Association, Inc. v. Bruen" (2022) assured the right to carry weapons in public spaces with reasonable exceptions.


text: The Second Amendment was based partially on the right to keep and bear arms in English common law and was influenced by the English Bill of Rights of 1689. Sir William Blackstone described this right as an auxiliary right, supporting the natural rights of self-defense and resistance to oppression, and the civic duty to act in concert in defense of the state. Any labels of rights as auxiliary must be viewed in the context of the inherent purpose of a Bill of Rights, which is to empower a group with the ability to achieve a mutually desired outcome, and not to necessarily enumerate or rank the importance of rights. While both James Monroe and John Adams supported the Constitution being ratified, its most influential framer was James Madison. In Federalist No. 46, Madison wrote how a federal army could be kept in check by state militias, "a standing army... would be opposed [by] a militia." He argued that state militias "would be able to repel the danger" of a federal army, "It may well be doubted, whether a militia thus circumstanced could ever be conquered by such a proportion of regular troops." He contrasted the federal government of the United States to the European kingdoms, which he described as "afraid to trust the people with arms", and assured that "the existence of subordinate governments... forms a barrier against the enterprises of ambition".


text: By January 1788, Delaware, Pennsylvania, New Jersey, Georgia and Connecticut ratified the Constitution without insisting upon amendments. Several amendments were proposed, but were not adopted at the time the Constitution was ratified. For example, the Pennsylvania convention debated fifteen amendments, one of which concerned the right of the people to be armed, another with the militia. The Massachusetts convention also ratified the Constitution with an attached list of proposed amendments. In the end, the ratification convention was so evenly divided between those for and against the Constitution that the federalists agreed to the Bill of Rights to assure ratification. In "United States v. Cruikshank" (1876), the Supreme Court ruled that, "The right to bear arms is not granted by the Constitution; neither is it in any manner dependent upon that instrument for its existence. The Second Amendments means no more than that it shall not be infringed by Congress, and has no other effect than to restrict the powers of the National Government." In "United States v. Miller" (1939), the Supreme Court ruled that the Second Amendment did not protect weapon types not having a "reasonable relationship to the preservation or efficiency of a well regulated militia".


text: In the 21st century, the amendment has been subjected to renewed academic inquiry and judicial interest. In "District of Columbia v. Heller", the Supreme Court handed down a landmark decision that held the amendment protects an individual's right to keep a gun for self-defense. This was the first time the Court had ruled that the Second Amendment guarantees an individual's right to own a gun. In "McDonald v. Chicago" (2010), the Supreme Court clarified that the Due Process Clause of the Fourteenth Amendment incorporated the Second Amendment against state and local governments. In "Caetano v. Massachusetts" (2016), the Supreme Court reiterated its earlier rulings that "the Second Amendment extends, prima facie, to all instruments that constitute bearable arms, even those that were not in existence at the time of the founding" and that its protection is not limited to "only those weapons useful in warfare". The debate between various organizations regarding gun control and gun rights continues.


text: There are several versions of the text of the Second Amendment, each with capitalization or punctuation differences. Differences exist between the version passed by Congress and put on display and the versions ratified by the states. These differences have been a focus of debate regarding the meaning of the amendment, particularly regarding the importance of what the courts have called the prefatory clause.


text: The final, handwritten original of the Bill of Rights as passed by Congress, with the rest of the original prepared by scribe William Lambert, is preserved in the National Archives. This is the version ratified by Delaware and used by the Supreme Court in "District of Columbia v. Heller":


text: The ratification acts from New York, Pennsylvania, Rhode Island, and South Carolina contained only one comma, but with differences in capitalization. Pennsylvania's act states:


text: The right for Protestants to bear arms in English history is regarded in English common law as a subordinate auxiliary right of the primary rights to personal security, personal liberty, and private property. According to Sir William Blackstone, "The... last auxiliary right of the subject... is that of having arms for their defence, suitable to their condition and degree, and such as are allowed by law. Which is... declared by... statute, and is indeed a public allowance, under due restrictions, of the natural right of resistance and self-preservation, when the sanctions of society and laws are found insufficient to restrain the violence of oppression."


text: The English Bill of Rights of 1689 emerged from a tempestuous period in English politics during which two issues were major sources of conflict: the authority of the King to govern without the consent of Parliament, and the role of Catholics in a country that was becoming ever more Protestant. Ultimately, the Catholic James II was overthrown in the Glorious Revolution, and his successors, the Protestants William III and Mary II, accepted the conditions that were codified in the Bill. One of the issues the Bill resolved was the authority of the King to disarm his subjects, after King Charles II and James II had disarmed many Protestants that were "suspected or knowne" of disliking the government, and had argued with Parliament over his desire to maintain a standing (or permanent) army. The bill states that it is acting to restore "ancient rights" trampled upon by James II, though some have argued that the English Bill of Rights created a new right to have arms, which developed out of a duty to have arms. In "District of Columbia v. Heller" (2008), the Supreme Court did not accept this view, remarking that the English right at the time of the passing of the English Bill of Rights was "clearly an individual right, having nothing whatsoever to do with service in the militia" and that it was a right not to be disarmed by the Crown and was not the granting of a new right to have arms.


text: The text of the English Bill of Rights of 1689 includes language protecting the right of Protestants against disarmament by the Crown, stating: "That the Subjects which are Protestants may have Arms for their Defence suitable to their Conditions and as allowed by Law." It also contained text that aspired to bind future Parliaments, though under English constitutional law no Parliament can bind any later Parliament.


text: The statement in the English Bill of Rights concerning the right to bear arms is often quoted only in the passage where it is written as above and not in its full context. In its full context it is clear that the bill was asserting the right of Protestant citizens not to be disarmed by the King without the consent of Parliament and was merely restoring rights to Protestants that the previous King briefly and unlawfully had removed. In its full context it reads:


text: Whereas the late King James the Second by the Assistance of diverse evil Councillors Judges and Ministers employed by him did endeavour to subvert and extirpate the Protestant Religion and the Laws and Liberties of this Kingdom "(list of grievances including)"... by causing several good Subjects being Protestants to be disarmed at the same time when Papists were both Armed and employed contrary to Law, "(Recital regarding the change of monarch)"... thereupon the said Lords Spiritual and Temporal and Commons pursuant to their respective Letters and Elections being now assembled in a full and free Representative of this Nation taking into their most serious Consideration the best means for attaining the Ends aforesaid Doe in the first place (as their Ancestors in like Case have usually done) for the Vindicating and Asserting their ancient Rights and Liberties, Declare "(list of rights including)"... That the Subjects which are Protestants may have Arms for their Defense suitable to their Conditions and as allowed by Law.


text: The historical link between the English Bill of Rights and the Second Amendment, which both codify an existing right and do not create a new one, has been acknowledged by the U.S. Supreme Court.


text: The English Bill of Rights includes the proviso that arms must be as "allowed by law". This has been the case before and after the passage of the Bill. While it did not override earlier restrictions on the ownership of guns for hunting, it is subject to the parliamentary right to implicitly or explicitly repeal earlier enactments.


text: There is some difference of opinion as to how revolutionary the events of 1688–89 actually were, and several commentators make the point that the provisions of the English Bill of Rights did not represent new laws, but rather stated existing rights. Mark Thompson wrote that, apart from determining the succession, the English Bill of Rights did "little more than set forth certain points of existing laws and simply secured to Englishmen the rights of which they were already ." Before and after the English Bill of Rights, the government could always disarm any individual or class of individuals it considered dangerous to the peace of the realm. In 1765, William Blackstone wrote the "Commentaries on the Laws of England" describing the right to have arms in England during the 18th century as a subordinate auxiliary right of the subject that was "also declared" in the English Bill of Rights.


text: Although there is little doubt that the writers of the Second Amendment were heavily influenced by the English Bill of Rights, it is a matter of interpretation as to whether they were intent on preserving the power to regulate arms to the states over the federal government (as the English Parliament had reserved for itself against the monarch) or whether it was intent on creating a new right akin to the right of others written into the Constitution (as the Supreme Court decided in "Heller"). Some in the United States have preferred the "rights" argument arguing that the English Bill of Rights had granted a right. The need to have arms for self-defence was not really in question. Peoples all around the world since time immemorial had armed themselves for the protection of themselves and others, and as organized nations began to appear these arrangements had been extended to the protection of the state. Without a regular army and police force, it had been the duty of certain men to keep watch and ward at night and to confront and capture suspicious persons. Every subject had an obligation to protect the king's peace and assist in the suppression of riots.


text: In 1757 Great Britain's Parliament created "An Act for better ordering of the militia forces in the several counties of that part of Great Britain called England". This act declared that a well-ordered and well-disciplined militia was essentially necessary to the safety, peace and prosperity of the English Kingdom, and that the current militia laws for the regulation of the militia were defective and ineffectual. Influenced by this act, in 1775 Timothy Pickering created "An Easy Plan of Discipline for a Militia". Greatly inhibited by the events surrounding Salem Massachusetts, where the plan was printed, Pickering submitted the writing to George Washington. On May 1, 1776, the Massachusetts Bay Councell resolved that Pickering's discipline, a modification of the 1757 act, be the discipline of their Militia. On March 29, 1779, for members of the Continental Army this was replaced by Von Steuben's Regulations for the Order and Discipline of the Troops of the United States. With ratification of the Second Amendment, after May 8, 1792, the entire United States Militia, barring two declarations, would be regulated by Von Steuben's Discipline.


text: Settlers in Colonial America viewed the "right to arms" and/or "the right to bear arms" and/or "state militias" as important for one or more of these purposes (in no particular order):


text: Which of these considerations were thought of as most important and ultimately found expression in the Second Amendment is disputed. Some of these purposes were explicitly mentioned in early state constitutions; for example, the Pennsylvania Constitution of 1776 asserted that, "the people have a right to bear arms for the defence of themselves and the state."


text: During the 1760s pre-revolutionary period, the established colonial militia was composed of colonists, including many who were loyal to British rule. As defiance and opposition to British rule developed, a distrust of these Loyalists in the militia became widespread among the colonists known as Patriots, who favored independence from British rule. As a result, some Patriots created their own militias that excluded the Loyalists and then sought to stock independent armories for their militias. In response to this arms build-up, the British parliament established an embargo of firearms, parts and ammunition against the American colonies. King George III also began disarming individuals who were in the most rebellious areas in the 1760s and 1770s.


text: British and Loyalist efforts to disarm the colonial Patriot militia armories in the early phases of the American Revolution resulted in the Patriot colonists protesting by citing the Declaration of Rights, Blackstone's summary of the Declaration of Rights, their own militia laws and common law rights to self-defense. While British policy in the early phases of the Revolution clearly aimed to prevent coordinated action by the Patriot militia, some have argued that there is no evidence that the British sought to restrict the traditional common law right of self-defense. Patrick J. Charles disputes these claims citing similar disarming by the patriots and challenging those scholars' interpretation of Blackstone.


text: The right of the colonists to arms and rebellion against oppression was asserted, for example, in a pre-revolutionary newspaper editorial in 1769 objecting to the Crown suppression of colonial opposition to the Townshend Acts:


text: The armed forces that won the American Revolution consisted of the standing Continental Army created by the Continental Congress, together with regular French army and naval forces and various state and regional militia units. In opposition, the British forces consisted of a mixture of the standing British Army, Loyalist militia and Hessian mercenaries. Following the Revolution, the United States was governed by the Articles of Confederation. Federalists argued that this government had an unworkable division of power between Congress and the states, which caused military weakness, as the standing army was reduced to as few as 80 men. They considered it to be bad that there was no effective federal military crackdown on an armed tax rebellion in western Massachusetts known as Shays' Rebellion. Anti-federalists, on the other hand, took the side of limited government and sympathized with the rebels, many of whom were former Revolutionary War soldiers. Subsequently, the Constitutional Convention proposed in 1787 to grant Congress exclusive power to raise and support a standing army and navy of unlimited size. Anti-federalists objected to the shift of power from the states to the federal government, but as adoption of the Constitution became more and more likely, they shifted their strategy to establishing a bill of rights that would put some limits on federal power.


text: Modern scholars Thomas B. McAffee and Michael J. Quinlan have stated that James Madison "did not invent the right to keep and bear arms when he drafted the Second Amendment; the right was pre-existing at both common law and in the early state constitutions." In contrast, historian Jack Rakove suggests that Madison's intention in framing the Second Amendment was to provide assurances to moderate Anti-Federalists that the militias would not be disarmed.


text: One aspect of the gun control debate is the conflict between gun control laws and the right to rebel against unjust governments. Blackstone in his Commentaries alluded to this right to rebel as the natural right of resistance and self preservation, to be used only as a last resort, exercisable when "the sanctions of society and laws are found insufficient to restrain the violence of oppression". Some believe that the framers of the Bill of Rights sought to balance not just political power, but also military power, between the people, the states and the nation, as Alexander Hamilton explained in his Concerning the Militia essay published in 1788:


text: Some scholars have said that it is wrong to read a right of armed insurrection into the Second Amendment because clearly the founding fathers sought to place trust in the power of the ordered liberty of democratic government versus the anarchy of insurrectionists. Other writers, such as Glenn Reynolds, contend that the framers did believe in an individual right to armed insurrection. They cite examples, such as the Declaration of Independence (describing in 1776 "the Right of the People to... institute new Government") and the Constitution of New Hampshire (stating in 1784 that "nonresistance against arbitrary power, and oppression, is absurd, slavish, and destructive of the good and happiness of mankind").


text: There was an ongoing debate beginning in 1789 about "the people" fighting governmental tyranny (as described by Anti-Federalists); or the risk of mob rule of "the people" (as described by the Federalists) related to the increasingly violent French Revolution. A widespread fear, during the debates on ratifying the Constitution, was the possibility of a military takeover of the states by the federal government, which could happen if the Congress passed laws prohibiting states from arming citizens, or prohibiting citizens from arming themselves. Though it has been argued that the states lost the power to arm their citizens when the power to arm the militia was transferred from the states to the federal government by ArticleI, Section8 of the Constitution, the individual right to arm was retained and strengthened by the Militia Acts of 1792 and the similar act of 1795.


text: In March 1785, delegates from Virginia and Maryland assembled at the Mount Vernon Conference to fashion a remedy to the inefficiencies of the Articles of Confederation. The following year, at a meeting in Annapolis, Maryland, 12 delegates from five states (New Jersey, New York, Pennsylvania, Delaware, and Virginia) met and drew up a list of problems with the current government model. At its conclusion, the delegates scheduled a follow-up meeting in Philadelphia, Pennsylvania for May 1787 to present solutions to these problems, such as the absence of:


text: It quickly became apparent that the solution to all three of these problems required shifting control of the states' militias to the federal Congress and giving it the power to raise a standing army. Article 1, Section 8 of the Constitution codified these changes by allowing the Congress to provide for the common defense and general welfare of the United States by doing the following:


text: Some representatives mistrusted proposals to enlarge federal powers, because they were concerned about the inherent risks of centralizing power. Federalists, including James Madison, initially argued that a bill of rights was unnecessary, sufficiently confident that the federal government could never raise a standing army powerful enough to overcome a militia. Federalist Noah Webster argued that an armed populace would have no trouble resisting the potential threat to liberty of a standing army. Anti-federalists, on the other hand, advocated amending the Constitution with clearly defined and enumerated rights providing more explicit constraints on the new government. Many Anti-federalists feared the new federal government would choose to disarm state militias. Federalists countered that in listing only certain rights, unlisted rights might lose protection. The Federalists realized there was insufficient support to ratify the Constitution without a bill of rights and so they promised to support amending the Constitution to add a bill of rights following the Constitution's adoption. This compromise persuaded enough Anti-federalists to vote for the Constitution, allowing for ratification. The Constitution was declared ratified on June 21, 1788, when nine of the original thirteen states had ratified it. The remaining four states later followed suit, although the last two states, North Carolina and Rhode Island, ratified only after Congress had passed the Bill of Rights and sent it to the states for ratification. James Madison drafted what ultimately became the Bill of Rights, which was proposed by the first Congress on June 8, 1789, and was adopted on December 15, 1791.


text: The debate surrounding the Constitution's ratification is of practical importance, particularly to adherents of originalist and strict constructionist legal theories. In the context of such legal theories and elsewhere, it is important to understand the language of the Constitution in terms of what that language meant to the people who wrote and ratified the Constitution.


text: Robert Whitehill, a delegate from Pennsylvania, sought to clarify the draft Constitution with a bill of rights explicitly granting individuals the right to hunt on their own land in season, though Whitehill's language was never debated.


text: There was substantial opposition to the new Constitution because it moved the power to arm the state militias from the states to the federal government. This created a fear that the federal government, by neglecting the upkeep of the militia, could have overwhelming military force at its disposal through its power to maintain a standing army and navy, leading to a confrontation with the states, encroaching on the states' reserved powers and even engaging in a military takeover. Article VI of the Articles of Confederation states:


text: No vessel of war shall be kept up in time of peace by any State, except such number only, as shall be deemed necessary by the united States in congress assembled, for the defense of such State, or its trade; nor shall any body of forces be kept up by any State in time of peace, except such number only, as in the judgement of the united States, in congress assembled, shall be deemed requisite to garrison the forts necessary for the defense of such State; but every State shall always keep up a well-regulated and disciplined militia, sufficiently armed and accoutered, and shall provide and constantly have ready for use, in public stores, a due number of field pieces and tents, and a proper quantity of arms, ammunition and camp equipage.


text: To provide for organizing, arming, and disciplining, the Militia, and for governing such Part of them as may be employed in the Service of the United States, reserving to the States respectively, the Appointment of the Officers, and the Authority of training the Militia according to the discipline prescribed by Congress.


text: A foundation of American political thought during the Revolutionary period was concerned about political corruption and governmental tyranny. Even the federalists, fending off their opponents who accused them of creating an oppressive regime, were careful to acknowledge the risks of tyranny. Against that backdrop, the framers saw the personal right to bear arms as a potential check against tyranny. Theodore Sedgwick of Massachusetts expressed this sentiment by declaring that it is "a chimerical idea to suppose that a country like this could ever be enslaved... Is it possible... that an army could be raised for the purpose of enslaving themselves or their brethren? Or, if raised whether they could subdue a nation of freemen, who know how to prize liberty and who have arms in their hands?" Noah Webster similarly argued:


text: Before a standing army can rule the people must be disarmed; as they are in almost every kingdom in Europe. The supreme power in America cannot enforce unjust laws by the sword; because the whole body of the people are armed, and constitute a force superior to any band of regular troops that can be, on any pretence, raised in the United States.


text: George Mason also argued the importance of the militia and right to bear arms by reminding his compatriots of the British government's efforts "to disarm the people; that it was the best and most effectual way to enslave them... by totally disusing and neglecting the militia." He also clarified that under prevailing practice the militia included all people, rich and poor. "Who are the militia? They consist now of the whole people, except a few public officers." Because all were members of the militia, all enjoyed the right to individually bear arms to serve therein.


text: Writing after the ratification of the Constitution, but before the election of the first Congress, James Monroe included "the right to keep and bear arms" in a list of basic "human rights", which he proposed to be added to the Constitution.


text: Patrick Henry argued in the Virginia ratification convention on June 5, 1788, for the dual rights to arms and resistance to oppression:


text: Guard with jealous attention the public liberty. Suspect everyone who approaches that jewel. Unfortunately, nothing will preserve it but downright force. Whenever you give up that force, you are inevitably ruined.


text: In the slave states, the militia was available for military operations, but its biggest function was to police the slaves. According to Dr Carl T. Bogus, Professor of Law of the Roger Williams University Law School in Rhode Island, the Second Amendment was written to assure the Southern states that Congress would not undermine the slave system by using its newly acquired constitutional authority over the militia to disarm the state militia and thereby destroy the South's principal instrument of slave control.


text: In his close analysis of James Madison's writings, Bogus describes the South's obsession with militias during the ratification process:


text: Therefore, Bogus argues, in a compromise with the slave states, and to reassure Patrick Henry, George Mason and other slaveholders that they would be able to keep their slave control militias independent of the federal government, James Madison (also slave owner) redrafted the Second Amendment into its current form "for the specific purpose of assuring the Southern states, and particularly his constituents in Virginia, that the federal government would not undermine their security against slave insurrection by disarming the militia."


text: Legal historian Paul Finkelman argues that this scenario is implausible. Henry and Mason were political enemies of Madison's, and neither man was in Congress at the time Madison drafted Bill of Rights; moreover, Patrick Henry argued against the ratification of both the Constitution and the Second Amendment, and it was Henry's opposition that led Patrick's home state of Virginia to be the last to ratify.


text: Most Southern white men between the ages of 18 and 45 were required to serve on "slave patrols" which were organized groups of white men who enforced discipline upon enslaved blacks. Bogus writes with respect to Georgia laws passed in 1755 and 1757 in this context: "The Georgia statutes required patrols, under the direction of commissioned militia officers, to examine every plantation each month and authorized them to search 'all Negro Houses for offensive Weapons and Ammunition' and to apprehend and give twenty lashes to any slave found outside plantation grounds."


text: Finkelman recognises that James Madison "drafted an amendment to protect the right of the states to maintain their militias," but insists that "The amendment had nothing to do with state police powers, which were the basis of slave patrols."


text: Firstly, slave owners feared that enslaved blacks might be emancipated through military service. A few years earlier, there had been a precedent when Lord Dunmore offered freedom to slaves who escaped and joined his forces with "Liberty to Slaves" stitched onto their jacket pocket flaps. Freed slaves also served in General Washington's army.


text: Secondly, they also greatly feared "a ruinous slave rebellion in which their families would be slaughtered and their property destroyed." When Virginia ratified the Bill of Rights on December 15, 1791, the Haitian Revolution, a successful slave rebellion, was under way. The right to bear arms was therefore deliberately tied to membership in a militia by the slaveholder and chief drafter of the Amendment, James Madison, because only whites could join militias in the South.


text: In 1776, Thomas Jefferson had submitted a draft constitution for Virginia that said "no freeman shall ever be debarred the use of arms within his own lands or tenements". According to Picadio, this version was rejected because "it would have given to free blacks the constitutional right to have firearms".


text: James Madison's initial proposal for a bill of rights was brought to the floor of the House of Representatives on June 8, 1789, during the first session of Congress. The initial proposed passage relating to arms was:


text: On July 21, Madison again raised the issue of his bill and proposed that a select committee be created to report on it. The House voted in favor of Madison's motion, and the Bill of Rights entered committee for review. The committee returned to the House a reworded version of the Second Amendment on July 28. On August 17, that version was read into the "Journal":


text: In late August 1789, the House debated and modified the Second Amendment. These debates revolved primarily around the risk of "mal-administration of the government" using the "religiously scrupulous" clause to destroy the militia as British forces had attempted to destroy the Patriot militia at the commencement of the American Revolution. These concerns were addressed by modifying the final clause, and on August 24, the House sent the following version to the Senate:


text: The next day, August 25, the Senate received the amendment from the House and entered it into the Senate Journal. However, the Senate scribe added a comma before "shall not be infringed" and changed the semicolon separating that phrase from the religious exemption portion to a comma:


text: By this time, the proposed right to keep and bear arms was in a separate amendment, instead of being in a single amendment together with other proposed rights such as the due process right. As a representative explained, this change allowed each amendment to "be passed upon distinctly by the States". On September 4, the Senate voted to change the language of the Second Amendment by removing the definition of militia, and striking the conscientious objector clause:


text: The Senate returned to this amendment for a final time on September 9. A proposal to insert the words "for the common defence" next to the words "bear arms" was defeated. A motion passed to replace the words "the best", and insert in lieu thereof "necessary to the" . The Senate then slightly modified the language to read as the fourth article and voted to return the Bill of Rights to the House. The final version by the Senate was amended to read as:


text: The enrolled original Joint Resolution passed by Congress on September 25, 1789, on permanent display in the Rotunda, reads as:


text: On December 15, 1791, the Bill of Rights (the first ten amendments to the Constitution) was adopted, having been ratified by three-fourths of the states, having been ratified as a group by all the fourteen states then in existence except Connecticut, Massachusetts, and Georgiawhich added ratifications in 1939.


text: During the first two decades following the ratification of the Second Amendment, public opposition to standing armies, among Anti-Federalists and Federalists alike, persisted and manifested itself locally as a general reluctance to create a professional armed police force, instead relying on county sheriffs, constables and night watchmen to enforce local ordinances. Though sometimes compensated, often these positions were unpaidheld as a matter of civic duty. In these early decades, law enforcement officers were rarely armed with firearms, using billy clubs as their sole defensive weapons. In serious emergencies, a "posse comitatus", militia company, or group of vigilantes assumed law enforcement duties; these individuals were more likely than the local sheriff to be armed with firearms.


text: On May 8, 1792, Congress passed "[a]n act more effectually to provide for the National Defence, by establishing an Uniform Militia throughout the United States" requiring:


text: The act also gave specific instructions to domestic weapon manufacturers "that from and after five years from the passing of this act, muskets for arming the militia as herein required, shall be of bores sufficient for balls of the eighteenth part of a pound." In practice, private acquisition and maintenance of rifles and muskets meeting specifications and readily available for militia duty proved problematic; estimates of compliance ranged from 10 to 65 percent. Compliance with the enrollment provisions was also poor. In addition to the exemptions granted by the law for custom-house officers and their clerks, post-officers and stage drivers employed in the care and conveyance of U.S. mail, ferrymen, export inspectors, pilots, merchant mariners and those deployed at sea in active service; state legislatures granted numerous exemptions under Section 2 of the Act, including exemptions for: clergy, conscientious objectors, teachers, students, and jurors. Though a number of able-bodied white men remained available for service, many simply did not show up for militia duty. Penalties for failure to appear were enforced sporadically and selectively. None is mentioned in the legislation.


text: The first test of the militia system occurred in July 1794, when a group of disaffected Pennsylvania farmers rebelled against federal tax collectors whom they viewed as illegitimate tools of tyrannical power. Attempts by the four adjoining states to raise a militia for nationalization to suppress the insurrection proved inadequate. When officials resorted to drafting men, they faced bitter resistance. Forthcoming soldiers consisted primarily of draftees or paid substitutes as well as poor enlistees lured by enlistment bonuses. The officers, however, were of a higher quality, responding out of a sense of civic duty and patriotism, and generally critical of the rank and file. Most of the 13,000 soldiers lacked the required weaponry; the war department provided nearly two-thirds of them with guns. In October, President George Washington and General Harry Lee marched on the 7,000 rebels who conceded without fighting. The episode provoked criticism of the citizen militia and inspired calls for a universal militia. Secretary of War Henry Knox and Vice President John Adams had lobbied Congress to establish federal armories to stock imported weapons and encourage domestic production. Congress did subsequently pass "[a]n act for the erecting and repairing of Arsenals and Magazines" on April 2, 1794, two months prior to the insurrection. Nevertheless, the militia continued to deteriorate and twenty years later, the militia's poor condition contributed to several losses in the War of 1812, including the sacking of Washington, D.C., and the burning of the White House in 1814.


text: In the 20th century, Congress passed the Militia Act of 1903. The act defined the militia as every able-bodied male aged 18 to 44 who was a citizen or intended to become one. The militia was then divided by the act into the United States National Guard and the unorganized Reserve Militia.


text: Federal law continues to define the militia as all able-bodied males aged 17 to 44, who are citizens or intend to become one, and female citizens who are members of the National Guard. The militia is divided into the organized militia, which consists of the National Guard and Naval Militia, and the unorganized militia.


text: In May of 1788, the pseudonymous author "Federal Farmer" (his real identity is presumed to be either Richard Henry Lee or Melancton Smith) wrote in "Additional Letters From The Federal Farmer #169" or "Letter XVIII" regarding the definition of a "militia":


text: The earliest published commentary on the Second Amendment by a major constitutional theorist was by St. George Tucker. He annotated a five-volume edition of Sir William Blackstone's "Commentaries on the Laws of England", a critical legal reference for early American attorneys published in 1803. Tucker wrote:


text: In footnotes 40 and 41 of the "Commentaries", Tucker stated that the right to bear arms under the Second Amendment was not subject to the restrictions that were part of English law: "The right of the people to keep and bear arms shall not be infringed. Amendments to C. U. S. Art. 4, and this without any qualification as to their condition or degree, as is the case in the British government" and "whoever examines the forest, and game laws in the British code, will readily perceive that the right of keeping arms is effectually taken away from the people of England." Blackstone himself also commented on English game laws, Vol. II, p. 412, "that the prevention of popular insurrections and resistance to government by disarming the bulk of the people, is a reason oftener meant than avowed by the makers of the forest and game laws." Blackstone discussed the right of self-defense in a separate section of his treatise on the common law of crimes. Tucker's annotations for that latter section did not mention the Second Amendment but cited the standard works of English jurists such as Hawkins.


text: Further, Tucker criticized the English Bill of Rights for limiting gun ownership to the very wealthy, leaving the populace effectively disarmed, and expressed the hope that Americans "never cease to regard the right of keeping and bearing arms as the surest pledge of their liberty."


text: Tucker's commentary was soon followed, in 1825, by that of William Rawle in his landmark text "A View of the Constitution of the United States of America". Like Tucker, Rawle condemned England's "arbitrary code for the preservation of game", portraying that country as one that "boasts so much of its freedom", yet provides a right to "protestant subjects only" that it "cautiously describ[es] to be that of bearing arms for their defence" and reserves for "[a] very small proportion of the people[.]" In contrast, Rawle characterizes the second clause of the Second Amendment, which he calls the corollary clause, as a general prohibition against such capricious abuse of government power.


text: Rawle, long before the concept of incorporation was formally recognized by the courts, or Congress drafted the Fourteenth Amendment, contended that citizens could appeal to the Second Amendment should either the state or federal government attempt to disarm them. He did warn, however, that "this right [to bear arms] ought not... be abused to the disturbance of the public peace" and, paraphrasing Coke, observed: "An assemblage of persons with arms, for unlawful purpose, is an indictable offence, and even the carrying of arms abroad by a single individual, attended with circumstances giving just reason to fear that he purposes to make an unlawful use of them, would be sufficient cause to require him to give surety of the peace."


text: Joseph Story articulated in his influential "Commentaries on the Constitution" the orthodox view of the Second Amendment, which he viewed as the amendment's clear meaning:


text: Story describes a militia as the "natural defence of a free country", both against foreign foes, domestic revolts and usurpation by rulers. The book regards the militia as a "moral check" against both usurpation and the arbitrary use of power, while expressing distress at the growing indifference of the American people to maintaining such an organized militia, which could lead to the undermining of the protection of the Second Amendment.


text: Abolitionist Lysander Spooner, commenting on bills of rights, stated that the object of all bills of rights is to assert the rights of individuals against the government and that the Second Amendment right to keep and bear arms was in support of the right to resist government oppression, as the only security against the tyranny of government lies in forcible resistance to injustice, for injustice will certainly be executed, unless forcibly resisted. Spooner's theory provided the intellectual foundation for John Brown and other radical abolitionists who believed that arming slaves was not only morally justified, but entirely consistent with the Second Amendment. An express connection between this right and the Second Amendment was drawn by Lysander Spooner who commented that a "right of resistance" is protected by both the right to trial by jury and the Second Amendment.


text: The congressional debate on the proposed Fourteenth Amendment concentrated on what the Southern States were doing to harm the newly freed slaves, including disarming the former slaves.


text: In 1867, Judge Timothy Farrar published his "Manual of the Constitution of the United States of America", which was written when the Fourteenth Amendment was "in the process of adoption by the State legislatures":


text: Judge Thomas M. Cooley, perhaps the most widely read constitutional scholar of the nineteenth century, wrote extensively about this amendment, and he explained in 1880 how the Second Amendment protected the "right of the people":


text: It might be supposed from the phraseology of this provision that the right to keep and bear arms was only guaranteed to the militia; but this would be an interpretation not warranted by the intent. The militia, as has been elsewhere explained, consists of those persons who, under the law, are liable to the performance of military duty, and are officered and enrolled for service when called upon. But the law may make provision for the enrolment of all who are fit to perform military duty, or of a small number only, or it may wholly omit to make any provision at all; and if the right were limited to those enrolled, the purpose of this guaranty might be defeated altogether by the action or neglect to act of the government it was meant to hold in check. The meaning of the provision undoubtedly is, that the people, from whom the militia must be taken, shall have the right to keep and bear arms; and they need no permission or regulation of law for the purpose. But this enables the government to have a well-regulated militia; for to bear arms implies something more than the mere keeping; it implies the learning to handle and use them in a way that makes those who keep them ready for their efficient use; in other words, it implies the right to meet for voluntary discipline in arms, observing in doing so the laws of public order.


text: Until the late 20th century, there was little scholarly commentary of the Second Amendment. In the latter half of the 20th century, there was considerable debate over whether the Second Amendment protected an individual right or a collective right. The debate centered on whether the prefatory clause ("A well regulated militia being necessary to the security of a free State") declared the amendment's only purpose or merely announced a purpose to introduce the operative clause ("the right of the People to keep and bear arms shall not be infringed"). Scholars advanced three competing theoretical models for how the prefatory clause should be interpreted.


text: The first, known as the "states' rights" or "collective right" model, held that the Second Amendment does not apply to individuals; rather, it recognizes the right of each state to arm its militia. Under this approach, citizens "have no right to keep or bear arms, but the states have a collective right to have the National Guard". Advocates of collective rights models argued that the Second Amendment was written to prevent the federal government from disarming state militias, rather than to secure an individual right to possess firearms. Prior to 2001, every circuit court decision that interpreted the Second Amendment endorsed the "collective right" model. However, beginning with the Fifth Circuit's opinion "United States v. Emerson" in 2001, some circuit courts recognized that the Second Amendment protects an individual right to bear arms.


text: The second, known as the "sophisticated collective right model", held that the Second Amendment recognizes some limited individual right. However, this individual right could be exercised only by actively participating members of a functioning, organized state militia. Some scholars have argued that the "sophisticated collective rights model" is, in fact, the functional equivalent of the "collective rights model". Other commentators have observed that prior to "Emerson", five circuit courts specifically endorsed the "sophisticated collective right model".


text: The third, known as the "standard model", held that the Second Amendment recognized the personal right of individuals to keep and bear arms. Supporters of this model argued that "although the first clause may describe a general purpose for the amendment, the second clause is controlling and therefore the amendment confers an individual right 'of the people' to keep and bear arms". Additionally, scholars who favored this model argued the "absence of founding-era militias mentioned in the Amendment's preamble does not render it a 'dead letter' because the preamble is a 'philosophical declaration' safeguarding militias and is but one of multiple 'civic purposes' for which the Amendment was enacted".


text: Under both of the collective right models, the opening phrase was considered essential as a pre-condition for the main clause. These interpretations held that this was a grammar structure that was common during that era and that this grammar dictated that the Second Amendment protected a collective right to firearms to the extent necessary for militia duty. However, under the standard model, the opening phrase was believed to be prefatory or amplifying to the operative clause. The opening phrase was meant as a non-exclusive exampleone of many reasons for the amendment. This interpretation is consistent with the position that the Second Amendment protects a modified individual right.


text: The question of a collective right versus an individual right was progressively resolved in favor of the individual rights model, beginning with the Fifth Circuit ruling in "United States v. Emerson" (2001), along with the Supreme Court's rulings in "District of Columbia v. Heller" (2008), and "McDonald v. Chicago" (2010). In "Heller", the Supreme Court resolved any remaining circuit splits by ruling that the Second Amendment protects an individual right. Although the Second Amendment is the only Constitutional amendment with a prefatory clause, such linguistic constructions were widely used elsewhere in the late eighteenth century.


text: Warren E. Burger, a conservative Republican appointed chief justice of the United States by President Richard Nixon, wrote in 1990 following his retirement:


text: The Constitution of the United States, in its Second Amendment, guarantees a "right of the people to keep and bear arms". However, the meaning of this clause cannot be understood except by looking to the purpose, the setting and the objectives of the draftsmen... People of that day were apprehensive about the new "monster" national government presented to them, and this helps explain the language and purpose of the Second Amendment... We see that the need for a state militia was the predicate of the "right" guaranteed; in short, it was declared "necessary" in order to have a state military force to protect the security of the state.


text: If I were writing the Bill of Rights now, there wouldn't be any such thing as the Second Amendment... that a well regulated militia being necessary for the defense of the state, the peoples' rights to bear arms. This has been the subject of one of the greatest pieces of fraudI repeat the word 'fraud'on the American public by special interest groups that I have ever seen in my lifetime.


text: For more than 200 years, the federal courts have unanimously determined that the Second Amendment concerns only the arming of the people in service to an organized state militia; it does not guarantee immediate access to guns for private purposes. The nation can no longer afford to let the gun lobby's distortion of the Constitution cripple every reasonable attempt to implement an effective national policy toward guns and crime.


text: Research by Robert Spitzer found that every law journal article discussing the Second Amendment through 1959 "reflected the Second Amendment affects citizens only in connection with citizen service in a government organized


text: and regulated militia." Only beginning in 1960 did law journal articles begin to advocate an "individualist" view of gun ownership rights. The opposite of this "individualist" view of gun ownership rights is the "collective-right" theory, according to which the amendment protects a collective right of states to maintain militias or an individual right to keep and bear arms in connection with service in a militia (for this view see for example the quote of Justice John Paul Stevens in the Meaning of "well regulated militia" section below). In his book, "Six Amendments: How and Why We Should Change the Constitution", Justice John Paul Stevens for example submits the following revised Second Amendment: "A well regulated militia, being necessary to the security of a free state, the right of the people to keep and bear arms when serving in the militia shall not be infringed."


text: An early use of the phrase "well-regulated militia" may be found in Andrew Fletcher's 1698 "A Discourse of Government with Relation to Militias", as well as the phrase "ordinary and ill-regulated militia". Fletcher meant "regular" in the sense of regular military, and advocated the universal conscription and regular training of men of fighting age. Jefferson thought well of Fletcher, commenting that "the political principles of that patriot were worthy the purest periods of the British constitution. They are those which were in vigour."


text: The term "regulated" means "disciplined" or "trained". In "Heller", the U.S. Supreme Court stated that "[t]he adjective 'well-regulated' implies nothing more than the imposition of proper discipline and training."


text: In the year before the drafting of the Second Amendment, in Federalist No. 29 Alexander Hamilton wrote the following about "organizing", "disciplining", "arming", and "training". of the militia as specified in the enumerated powers:


text: Justice Scalia, writing for the Court in "Heller": "In "Nunn v. State", 1 Ga. 243, 251 (1846), the Georgia Supreme Court construed the Second Amendment as protecting the 'natural right of self-defence' and therefore struck down a ban on carrying pistols openly. Its opinion perfectly captured the way in which the operative clause of the Second Amendment furthers the purpose announced in the prefatory clause, in continuity with the English right":


text: An earlier case, "United States v. Verdugo-Urquidez" (1990), dealt with nonresident aliens and the Fourth Amendment, but led to a discussion of who are "the People" when referred to elsewhere in the Constitution:


text: According to the majority in "Heller", there were several different reasons for this amendment, and protecting militias was only one of them; if protecting militias had been the only reason then the amendment could have instead referred to "the right of the "militia" to keep and bear arms" instead of "the right of the "people" to keep and bear arms".


text: In "Heller" the majority rejected the view that the term "to bear arms" implies only the military use of arms:


text: A search of Brigham Young University's new online Corpus of Founding Era American English, with more than 95,000 texts and 138 million words, yields 281 instances of the phrase "bear arms". BYU's Corpus of Early Modern English, with 40,000 texts and close to 1.3 billion words, shows 1,572 instances of the phrase. Subtracting about 350 duplicate matches, that leaves about 1,500 separate occurrences of "bear arms" in the 17th and 18th centuries, and only a handful don't refer to war, soldiering or organized, armed action. These databases confirm that the natural meaning of "bear arms" in the framers' day was military.


text: A paper from 2008 found that before 1820, the use of the phrase "bear arms" was commonly used in a civilian context, such as hunting and personal self-defense, in both American and British law. One scholar suggests that the right to "keep and bear arms" further includes a right to privately manufacture firearms.