The Miller court’s approach, which focused only on the relationship between the regulated arms at issue and the Second Amendment’s militia purpose was flawed because that approach would only allow individuals to possess arms suited for military use. Such an approach is obviously troublesome if it would allow private ownership of modern military arms.

Richard K. Willard
D.C. versus Heller
Brief amicus curiae Of The Heartland Institute in support of respondent.
[Indeed! Miller should be expanded to include arms suitable for private self-defense. That isn't what Willard has in mind but that is what I'm hoping the SCOTUS concludes. Of course Willard, in supporting D.C., is also troubled that individuals should have the right to defend themselves against anything. One can only conclude the relationship between the state and the individual is that of a rancher and his cattle. The rancher dehorns the cattle so they cannot easily defend themselves or seriously injury each other. The rancher takes it upon himself to defend the cattle from predators, provide their food, care for the sick, and to slaughter them as it may suit him.--Joe]