Finally! Proof positive that the right to keep and bear arms as described in the Second Amendment is, in fact, an individual right.
[I]t is not enough to consider keep and bear arms in a vacuum. The Second Amendment’s operative clause refers to “the right of the people.” We conducted another search in [Corpus of Founding Era American English] for documents that referenced arms in the context of rights.
About 40 percent of the results had a militia sense, about 25 percent used an individual sense, and about 30 percent referred to both militia and individual senses. The remainder were ambiguous.
With respect to rights, there was not a dominant sense for keeping and bearing arms. Here, too, an “ordinary citizen” at the time of the founding likely would have understood that the phrase arms, in the context of rights, referred to both militia-based and individual rights.
Based on these findings, we are more convinced by Scalia’s [Heller] majority opinion than Stevens’s dissent, even though they both made errors in their analysis. Furthermore, linguistic analysis formed only a small part of Scalia’s originalist opus. And the bulk of that historical analysis, based on the history of the common-law right to own a firearm, is undisturbed by our new findings.
– James C. Phillips and Josh Blackman in The Mysterious Meaning of the Second Amendment