“[Miller] was generally understood to limiting the scope of the Second Amendment to the uses of arms that were related to military activities. The Court did not overrule Miller [in Heller]. Instead it ‘read Miller to say only that the Second Amendment does not protect those weapons not typically possessed by law-abiding citizens for lawful purposes, such as short-barreled shotguns . . . Thus, the Second Amendment provides no obstacle to regulations permitting the ownership or the use of the sorts of the automatic weapons used in the tragic multiple killings in Virginia, Colorado, or Arizona in recent years.” – Retired Supreme Court Justice John Paul Stevens after a speech to the Brady Center to Prevent Gun Violence’s Legal Action Project
