The Second Amendment’s historical self-defense purpose should be used to define the scope of its protections. In our view, the Second Amendment protects the right to own firearms of a kind that are commonly used for self-defense by law-abiding individuals. We do not doubt that the government can outlaw private ownership of unusually destructive or exotic weapons. But private ownership of all handguns cannot be prohibited because handguns are the kind of weapon best suited for and most commonly owned for the purpose of self-defense.

Richard K. Willard
D.C. versus Heller
Brief Amicus Curiae Of The Heartland Institute in support of respondent.