When the Constitution was before the states for ratification, several expressed reservations and asked for unequivocal protection of individual rights. This led to the Bill of Rights.

Pennsylvania, the second state to ratify the Constitution, did so only after a minority report included the first explicit statement of what became the Second Amendment. It read: "That the people have a right to bear arms for the defence of themselves and their own state, or the United States, or for the purpose of killing game, and no law shall be passed for disarming the people or any of them, unless for crimes committed, or real danger of public injury from individuals."

Ratifying resolutions by other states included the word "militia." Typical was New York's: "That the people have a right to keep and bear arms; that a well regulated militia, including the body of the people capable of bearing arms, is the proper, natural, and safe defence of a free State."

Regardless of the current meaning of militia, the Bill of Rights' authors saw the militia as including all law-abiding citizens. In the end, the Second Amendment was written to protect the right of individuals to possess arms, and ultimately to be capable of defending themselves and their nation.