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He quotes Don Kates when explaining why the Second Amendment guarantees an individual right:

From the enactment of the Bill of Rights in 1791 until the 20th Century, no one seriously argued that the Second Amendment dealt with anything but an individual right—along with all other nine original amendments. Kates writes that not one court or commentator denied it was a right of individual gun owners until the last century. Judges and commentators in the 18th and 19th century routinely described the Second Amendment as a right of individuals. And they expressly compared it to the other rights such as speech, religion, and jury trial.

The Times has simply replayed theories invented by the 20th century gun control movement. Their painting of the individual right interpretation as a minority view is equally fanciful.

Kates writes that, "Over 120 law review articles have addressed the Second Amendment since 1980. The overwhelming majority affirm that it guarantees a right of individual gun owners. That is why the individual right view is called the 'standard model' view by supporters and opponents alike. With virtually no exceptions, the few articles to the contrary have been written by gun control advocates, mostly by people in the pay of the anti-gun lobby.