Wolford v. Lopez · ¶154

Specifically, Bruen relied heavily on Heller, which “demand[ed] a test rooted in the Second Amendment’s text, as informed by history.” 597 U. S., at 19 (emphasis added). According to Bruen, Heller had “relied on text and history” for “defining the character of the right . . . , suggesting the outer limits of the right, [and] assessing the constitutionality of a particular regulation.” Bruen, 597 U. S., at 22 (emphasis added). This characterization of Heller made sense, as the main point of Heller’s analysis was to explain that the text of the Second Amendment codified a pre-existing right. 554 U. S., at 592. History, then, was necessary for interpreting the text.

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