Wolford v. Lopez · ¶151

Although Bruen did not conduct a historical analysis itself, that was because Bruen's step-one “plain text” determination was obvious after Heller. In other words, the interpretive question the Bruen Court was asked to answer required no interpretation of the text of the Amendment beyond what Heller had done. 597 U. S., at 32. Heller had already reviewed the historical record and had essentially concluded that the proposed course of conduct at issue in Bruen—“carrying handguns publicly for self-defense”—was covered by the text of the Second Amendment. Bruen, 597 U. S., at 32 (citing Heller, 554 U. S., at 592). Indeed, the parties in Bruen did not dispute this point. 597 U. S., at 33.

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