Bringing Nunchakus to a Gun Fight: Examing the Hidden Frontline in the Second Amendment Debate
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BRINGING NUNCHAKUS TO A GUN FIGHT: EXAMINING THE
HIDDEN FRONTLINE IN THE SECOND AMENDMENT DEBATE
ALEX MATTHEWS
INTRODUCTION
The gun control debate continues to rage in the United States.' Neither
side wants to give an inch in pursuit of their vision of what gun rights
should or should not be in modem-day America.2 It seems all too often we
learn of a mass shooting involving numerous fatalities,3 so it comes as no
surprise that following every incident, a new wave of legislation is intro-
duced in an effort to prevent something similar from ever happening
again.4 However, such legislation may run afoul of the protections guaran-
teed under the Second Amendment to the Constitution of the United States.
The Second Amendment states, A well-regulated militia, being nec-
essary to the security of a free state, the right of the people to keep and bear
arms shall not be infringed.5 For most of this nation's history, the Su-
preme Court almost ignored the Second Amendment, refusing to grant
certiorari in cases centering on it.6 But that changed in 2008 when the Su-
preme Court heard District of Columbia v. Heller.' Two years later, the
Court heard another Second Amendment case, McDonald v. City of Chica-
go,8 and again six years after that in Caetano v. Massachusetts.9 While this
is not exactly an inundation of cases, it certainly displays a marked shift
from the manner in which the Court had treated the Second Amendment
1. See, e.g., Sheryl Gay Stolberg, Texas Shooting Brings New Urgency to Gun Debate in Con-
gress, N.Y. TIMES (Sept. 1, 2019), https://www.nytimes.com/2019/09/01/us/politics/texas-shooting-
gun-control.html. [https://perma.cc/5GK2-R6RA].
2. See id.
3. E.g., Elizabeth Chuck, Alex Johnson, & Corky Siemaszko, 17 Killed in Mass Shooting at
High School in Parkland, Florida, NBC NEWS (Feb. 14, 2018), www.nbcnews.com/news/us-
news/police-respond-shooting-parkland-florida-high-school-n84810 [https://perma.c/DvY9-Q3X8].
4. See Sotlberg, supra note 1.
5. U.S. CONST. amend. II.
6. E.g., United States v. Warin, 530 F.2d 103, 106-07 (6th Cir. 1976) (holding that the Second
Amendment does not guarantee a personal right to bear arms), cert. denied, 426 U.S. 948 (1976).
7. 554 U.S. 570 (2008).
8. 561 U.S. 742 (2010).
9. 136 S. Ct. 1027 (2016).
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Bringing Nunchakus to a Gun Fight: Examing the Hidden Frontline in the Second Amendment Debate
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