The right there specified is that of "bearing arms for a lawful purpose." This is not a right granted by the Constitution. Neither is it in any manner dependent upon that instrument for its existence. The second amendment declares that it shall not be infringed, but this, as has been seen, means no more than that it shall not be infringed by Congress. - US v. Cruikshank
1876 年聯邦最高法院在 US v. Cruikshank 一案的判詞裏說,合法持槍的權利不是憲法賦予的,也絕不依靠憲法而存在。