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Adam Winkler

Adam Winkler

Posted: June 27, 2008 09:17 PM

Justice Scalia's Living Constitution


One of the most intriguing aspects of Justice Scalia's opinion in District of Columbia v. Heller, the landmark Second Amendment decision handed down Thursday, is its use of living constitutionalism to justify the decision to invalidate D.C.'s handgun ban. On first look, the opinion appears to be an ode to originalism: the Court goes on for page after page detailing why and how the framers drafted the Second Amendment to protect an individual right to bear arms. But when it comes to deciding why the handgun ban is unconstitutional, Scalia, the most famous proponent of interpreting the Constitution strictly according to its original meaning, argues that handguns are the most popular weapons chosen by Americans for self-defense. But why should that matter? Since when does an originalist look to today's choices -- or the choices of recent generations -- to determine the scope of a constitutional right? If people had chosen machine guns as their weapon of choice, presumably they would be protected too. Sounds like the Constitution is evolving to fit current circumstances after all.

A true originalist approach might look to the weapons preferred by the Founding generation to determine what is protected. That's not what the Court did, perhaps fearing the logical consequence that a handgun ban might be permitted in light of the Founding generation's preference for the more reliable and accurate long gun.

So what is protected and what is not protected? That is where the Second Amendment rubber hits the road. The real meaning of the Second Amendment is in what the Court reads that Amendment to prohibit or allow. But here the opinion does not provide tremendous guidance, failing to articulate a standard of review to help the lower courts soon to face numerous Second Amendment suits. More importantly, the guidance it does give is not grounded in original meaning at all.

The Court says that it is not calling into question longstanding prohibitions on possession by felons and the mentally incompetent, bans on guns in sensitive places, and restrictions on sales and purchase. In another passage, the Court suggests that "dangerous and unusual" weapons and concealed weapons can be banned. Why doesn't the Second Amendment call those laws into question? The Court provides no answer other than that they are "longstanding." But this is not the same as "part of the original public meaning" of the Second Amendment. Indeed, many of these types of laws are modern inventions and - while reasonable and appropriate - had no analogy in the Founding era. The Founders didn't require background checks, require sellers to be licensed, or ban guns in schools. Mental incompetence was not even something recognized in the law until the 19th century. Meanwhile, the types of gun control laws the Framers did have would be unacceptable: requirements that all able-bodied men turn up for mandatory musters or that all gun owners take an oath of loyalty to the state.

Maybe a good originalist argument could be made to support the exceptions recognized in Justice Scalia's opinion. But Heller only stated the exceptions and cites no historical evidence whatsoever that the Founding generation understood the right to self-defense to be subject to these particular exceptions.

So what explains the reasonable regulations that Scalia's opinion recognizes? America's living tradition of the right to bear arms. Americans have enjoyed the right to bear arms in most states for most of American history and they have always accepted a wide array of reasonable gun control measures, including the very types of laws Scalia lists. In the end, the list is a product of that lived experience and development of the right to bear arms, not originalist interpretive method.

One of the most intriguing aspects of Justice Scalia's opinion in District of Columbia v. Heller, the landmark Second Amendment decision handed down Thursday, is its use of living constitutionalism to...
One of the most intriguing aspects of Justice Scalia's opinion in District of Columbia v. Heller, the landmark Second Amendment decision handed down Thursday, is its use of living constitutionalism to...
 
 
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HUFFPOST SUPER USER
LilyMaskew
Progressive, parent, happy, sensitive, woman
08:25 PM on 06/30/2008
It seems illogical to me that I can't have privacy on my telephone, internet, etc. - but I can own a gun. Can we swap our rights or sumthin'?
02:40 PM on 06/30/2008
I believe it's true that most Americans used muskets and rifles in rural areas but there were large cities during the time of the Founding Fathers. Phillidelphia, New York and Boston for example, were huge American cities. I don't believe that gentlemen walked the streets armed with 5 foot long muskets. So, either the cities were crime free in this time of poverty or gentlemen used pistols to defend themselves when walking the city streets. Yes, I've seen the pistols of the period. I've also seen the cloaks and long jackets worn by men of the period also. It wouldn't be hard to conceal a weapon under them.
Are those that disagree with allowing handguns for home defense advocating rifles for that purpose? It seems the author is. As early American citizens could own large, powerful, fast loading military muskets I believe todays comparison would be the assault weapon. Should DC residents be allowed an Assault weapon with which to defend themselves instead of a handgun? Then there were the early rifles. They were accurate and extremely deadly for the time period. Today's comparison would be a sniper rifle or possible a scoped hunting rifle. Should a homeowner in DC have a 30-06 or even .50 cal sniper rifle to defend themselves and their homes? I think a pistol is a much more reasonable defensive weapon for a city dweller and Scalia's ruling makes more sense than the authors.
05:28 PM on 06/30/2008
Pistols of any calibor are a terrible weapon to defend your home. The best weapon for home defense is a short barrel pump action shot gun.
09:03 PM on 06/30/2008
Pistols are actually good guns with which to defend your home. As Scalia said, "You can aim with one hand and dial 911 with the other." You can also open doors, turn on lights, etc while still aiming your weapon. If trouble is expected (example -an abusive ex just called and threatened you) then a pistol is much handier than a shotgun.
A shotgun however is much more intimidating than a handgun and has more stopping power. It is also more likely to be out of reach when needed. Then there is the fact that not everyone can handle a shotgun. Have you ever seen Bob Dole or McCain use their wounded arms? Many women and the elderly simple cannot handle a shotgun.
According to Edwin Marshal and James Sannow a .357 Magnum loaded with 125 gr JHP bullets has a 96-97% chance of stopping someonw with one shot to the torso. a .40 cal Semi Automatic loaded with 180 gr JHP has about the same stats. It's hard to see how a shotgun could do much better and still be as easily accessable as a pistol.
In the end you should use as much gun as you can safely and accurately handle. For some that's a 12 guage pump. For an elderly woman with arthritis it may be a .22 revolver.
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HUFFPOST COMMUNITY MODERATOR
lisakaz2
Da ministero dell'interno di Snark.
11:59 AM on 06/30/2008
Exactly. "Strict constructionism" was nothing more than a convenience or contrivance. I wouldn't put it past Scalia to cite it again despite the fact that his dismissal of it here means it is no longer relevant in jurisprudence by his OWN usage. He wants it both ways -- as do Bushies in general. No surprise. But Scalia WILL be surprised when his hypocricy will be used against him down the road -- as I'm sure it will be.
01:44 PM on 06/30/2008
Scalia is NOT a strict constructionist. That term is constantly misused by people who have no clue what it means, e.g., you. However, in this case, where we have an amendment that says the people have the "right to bear arms", strict constructionists, originalists, and people who can read have no problem coming to the reasonable conclusion that the "right to bear arms" means you have a right to bear arms.
02:47 PM on 06/30/2008
You seem to have the same idea about the Second Amendment that the NRA has: That it starts with an ellipsis. Instead, the Second Amendment reads:

A well regulated militia being necessary to the security of a free state, the right of the people to keep and bear arms shall not be infringed.

Clearly, the Second Amendment is about a militia being called to defend the state, not about your personal safety or your need to go hunting. The Second Amendment has always been interpreted this way because the text directly states that it is in reference to a militia.

Until now.

Hint: There is another Amendment that might indicate you have a right to a handgun for your personal protection or for hunting. Can you think of which Amendment it might be?
HUFFPOST SUPER USER
jmad
11:55 AM on 06/30/2008
The sad fact is that people pick apart any deal to justify their own twisted thinking.
In order to survive, our country needs a living breathing constitution. It is simply impossible for a two hundred year old document can possibly anticipate modern life.
The so called originalist supremes are no different.
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feo
huh?
11:55 AM on 06/30/2008
"Original intent" is just a law scholar's way of saying "intelligent design." Neither is provable, neither is knowable.
11:17 AM on 06/30/2008
Reminds me of the laughable " You play Bach your way and I'll play Bach HIS way" by Landowska.

Strict constitutional interpretation is a fantasy, not any more or any less than staged Gettysburg battle is a real battle. Or as "authentic" instrument interpretation playing of a Vivaldi concert is authentic.

It's sham mascaraing as justice.
In the end each one of justices simply uses his prejudices and tendencies to justify the mangling of the Constitution.
The people on the left and right do the same thing.
This is not a problem, as long as one invokes his/her opinion as justification, not some abysmally "this is what Constitution really means" stance..
HUFFPOST SUPER USER
FLGuardsman
11:16 AM on 06/30/2008
Scalia actually made a good decision on this one. The DC gun ban was impossible to enforce anyway. In his decision he still left room for handgun controls. I don't own a gun, nor have I ever. But, depending on the situation, I would want to be able to own one if I choose. Right now, I prefer to stick to my dog and mini louisville slugger. In close combat your odds are better with that than a gun anyway.
01:46 PM on 06/30/2008
The fun part was when the anti-handgun nut pundit Carl Rowan pulled a handgun on a group of teenagers who jumped in his pool. Just remember that liberalism (a la socialism, communism, etc) defines the rules for little people -- the elite class is more equal than others.
10:14 AM on 06/30/2008
There are supposed to be heavy penalties for those who commit crimes with guns now! Either the system works or it doesn't ...

OTOH. let's suppose we ban ALL driving because some people driving are 'under the influence' of alcohol. So let's have 'car control' yes? No? Is there any difference ? Would you trust your cousin with a car but not a pistol?
10:03 AM on 06/30/2008
I'm proud to say. I am licensed to conceal and carry. Thank you 2nd amendment.
10:00 AM on 06/30/2008
Originalism simply means that the Constitution should be applied with a reasonable interpretation of what the framers intended. Adam seems to be making the point that because the SC ruling wasn't restricted to muskets then the ruling can't be originalist. That is a pathetically weak and baseless foundation of debate. "Originalists" don't reject the notion of interpreting the Constitution to apply the logic behind original intent of the document to modern situations. They also accept the idea that rights are not absolute and must be balanced against other rights (e.g., the old argument that you can't yell "Fire" in a crowded movie theater and say it's protected by the First Amendment). Because Scalia acknowledges this in narrowing the scope of this opinion is not inconsistent with Scalia's originalist philosophy even though Adam tries (unsuccessfully) to make that the case.
10:21 AM on 06/30/2008
Originalism is a fraud. Original intent is supposed to provide an objective basis on which to interpret constitutional provisions; something other than judges' individual preferences. But of course it does no such thing, because the Founders took relatively little action to explain for the ages their intent behind each and every clause of the constitution. The Second Amendment is a perfect example because no one knows what the Founders really meant by it. Originalism is a means by which idealogues mask their personal preferences and dress them up as obeisance to the will of the Founding Fathers.

Also, look, it seems obvious to me that if the Second Amendment reference to "arms" was intended to mean anything, it was to refer to military-type firearms. It's obvious because the Amendment explicitly links the right to the maintenance of a militia. But Scalia can't go that far, so he conveniently drops originalism when it leads to an inconvenient conclusion.

The Republican Party today is fundamentally malign, and conservatives who still, to this day, continue to carry its water, cannot be argued with.
10:45 AM on 06/30/2008
Actually, Scalia is more of an "original meaning" guy (vs. "original intent"). He simply wants to make rulings based on a reasonable interpretation of the words (based on their "plain meaning" at the time they were written). Scalia's opinion brilliantly laid out the basis of the majority's foundation of original meaning of each word/phrase of the amendment. Perhaps you should take the time to actually read the opinion before you dismiss it based on your (obviously limited) understanding and biases.
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09:53 AM on 06/30/2008
Keep in mind that Scalia goes on canned hunts.
09:41 AM on 06/30/2008
I have a plan for gun control advocates:

First, you disarm the criminals. Then, you disarm the police. (In case you had not noticed, no-knock warrants, often served on some wrong address , often kill or wound innocent citizens.)

Then you disarm the military -- no 'friendly fire' accidents', or panic mistakes, etc.

Once the world is truly safe from other people's firearms, the rest of us can breathe easier, right?

Then you can start on the use of bladed weapons, like the crazy that killed seven people in Japan (which has extensive firearms bans) but killed those people with a knife.
09:12 AM on 06/30/2008
Seems to me the constitutional "orginalists" have exactly the same problem as the bible-thumping "literalists" have, in that they are forced to go through massive intellectual contortions to reconcile the obvious glaring contradictions in their respective sacred texts.
10:02 AM on 06/30/2008
Hmm, it's laughable that when the court finds that the 2nd amendment's "right to bear arms" means you have a right to bear arms, you call that a "contortion". I'm thinking it's the liberals who are the contortionists here.
HUFFPOST PUNDIT
Durango
10:30 AM on 06/30/2008
The contortion is in the reasoning applied

What I find remarkable is that many of the same people who are rejoicing in the decision on the 2nd Amendment are the same folks (including Scalia) outraged that the Supreme Court upheld the right of Habeus Corpus.

While they won't admit it, the 2nd Amendment was so poorly written it doesn't make sense.

But the Constitutional language on Habeus Corpus is as simple and clear as can be.

To any "originalists" out there. How come you cannot understand the original intent of the Constitution on Habeus Corpus? That it not be suspended except in times of Invasion or Rebellion.

How is that open to interpretation or in any way unclear.

And you know of course: The right to Habeus Corpus has done far more to secure the liberties of Americans than any gun collection anywhere.
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HUFFPOST COMMUNITY MODERATOR
lisakaz2
Da ministero dell'interno di Snark.
12:05 PM on 06/30/2008
Only by negating "well-regulated militia." Duh!
07:53 AM on 06/30/2008
Im not a Scalia fan but every blue moon or so he makes a decision I like.Im a liberal that cant see how a person is gonna be able to get his weapon out of the safe or put back together in time to defend himself from an intruder.I havent had a gun since I quit hunting in the 80s,but I believe in all our rights.I keep a loaded(loaded with noise,she wouldnt bite a flea) dog for protection.
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HUFFPOST SUPER USER
Torus34
A poor old country mouse.
07:07 AM on 06/30/2008
The gun issue illuminates quite nicely the meaningless of phrases such as 'strict constructionist' when measured against the real world.

Reflect, for a moment, on whether those who started the American Revolution were reactionaries, conservatives, progressives or radicals.