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Robert J. Spitzer

Robert J. Spitzer

Posted: June 29, 2010 10:19 AM

Incorporating Guns?

What's Your Reaction:

Pity poor John Barron. The Baltimore businessman found his business -- a wharf where ships docked -- ruined when the city's public works improvements resulted in the depositing of sand, gravel, and dirt off of the wharf and into the bay. The city refused to compensate Barron for his loss, so he sued, arguing that the Bill of Rights' Fifth Amendment, which says that private property was not to be taken "for public use without just compensation" should yield compensation for him. On its face, Barron's claim was just; nevertheless, the Supreme Court concluded in 1833 that Barron was out of luck because the Bill of Rights applied only to the national government, not the states.

Jump ahead to 1897 when the high court reversed course, ruling that the states must now abide by the just compensation protection. Why the change? The short answer is the addition of the Fourteenth Amendment to the Constitution in 1868, which said in part that states may not deprive persons of "life, liberty, or property, without due process of law." This wording eventually became the means by which the courts began to apply or "incorporate" parts of the Bill of Rights to the states, including free speech, free press, free exercise of religion, and most of the rest of the first eight amendments. By the time the court incorporated the Fifth Amendment's protection against double jeopardy in 1969, the consensus was that incorporation was probably at an end. As the piecemeal incorporation process suggested, not all Bill of Rights protections were equally important. No one was beating down the doors of judicial chambers to incorporate the Third Amendment's protection against the quartering of troops in people's homes in peacetime, or the Seventh Amendment's right to common law suits "where the value in controversy shall exceed twenty dollars," or, for that matter, the Second Amendment's militia-based right to keep and bear arms -- a right rendered obsolete with the decline of old-style militia system.

But the calculus changed for the Second Amendment in 2008, when the Supreme Court, for the first time in history, ruled that the amendment protected an individual right of civilians to own handguns for the purpose of personal self-protection in the home. The court's D.C. v. Heller decision was notable not only for rejecting its own past precedents, but for creating a new right built on what most historians considered a suspect reading of the amendment's history. Having carved out this new right, how could the five member majority in Heller not see the process through to incorporation? As Justice Anthony Kennedy noted twice during oral argument in McDonald v. Chicago, if the right to bear arms was an individual right (that is, unconnected to militia service), it must be fundamental -- that is, worthy of incorporation -- and "if it's not fundamental, then Heller is wrong."

When the court incorporated just compensation, free speech, and other civil liberties, it meant that states had to conform to a higher definition of these personal freedoms. Yes, it would mean protecting speech some found odious; countenancing unorthodox religious beliefs alien to a nation dominated by Judeo-Christian traditions; protecting the publication of xenophobic or racist utterances; occasionally releasing from prison suspects who seemed obviously guilty because of improper searches and seizures; and providing lawyers to people who couldn't afford to pay for them.

McDonald, though, does something else. It applies to persons, all right, but it does not enshrine a right to personal self-defense (that right has existed as bedrock law for centuries). Instead, it's a right (admittedly limited) to civilian gun ownership, which means, quite simply, a right to civilian-controlled deadly force. In a nation where ever-fewer citizens have guns, where crime has steadily declined across two decades, where police are more respected and efficient than ever, where the most frequent fatal use of guns is suicide, where violence against the government is increasingly seen by some as noble, and where we teach our children that it's better to talk over differences than fight about them, this court's McDonald is an anomaly.


Spitzer's books include Saving the Constitution From Lawyers, The Politics of Gun Control, and Gun Control.

 
 
 
 
 
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03:03 PM on 07/19/2010
"In a nation where ever-fewer citizens have guns..."

Not true, gun ownership has been going up steadily, as have the numbers of guns in private hands. And yet the crime rates go down...

Where is evidence of the "blood in the streets" mantra the anti-gun 'movement' constantly chants...?
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spacewalker
no time to hate
06:17 PM on 07/06/2010
Another post pulled for pointing out the obvious,this man is a gun control zealot using his views as a basis for being published as a "expert"on Constitutional law.Disingenuous is putting it mildly with respect to this mans view of the 2A and the Heller and Mcdonald rulings.One of his books is titled"Saving the Constitution from Lawyers",making it obvious he believes his opinion outweighs those who actually litigate cases in the court system of this Nation.Since the argument about individual vs. collective is now settled,and the incorporation of the 2A has been completed,people who detest fellow citizens having the ability to use deadly force to defend their lives and property from criminals must now try to change the way these rights are viewed by the public.Regular citizens don't have the training or common sense to judge when deadly force should be deployed,we can and must rely on the very trustworthy and efficient Police.Obviously Professor Spitzer lives far outside a crime ridden and drug plauged neighborhood where Police view all as suspect and constantly use stop and frisk tactics on citizens and where "contagious shooting"by officers is a regular occurance. In
the view from his Ivory Tower,the Police are trusted friends and fellow citizens are unworthy adversaries unable to judge when their own safety is in imminent danger.Streets turn into the wild west again and unlawful deployment of deadly force by citizens will become rampant.The facts just do not prove this to be the case.
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05:51 PM on 07/02/2010
Maybe disingenuous to say that "most historians" would consider the individual rights reading suspect. Should also mention that many historians think it's anomalous to say "the people" in the 2A is the state, while "the people" elsewhere in the constitution most definitely means the citizens.

Disingenuous again to say the most frequent fatal use of guns is suicide. Suicide rates don't go down in places where guns are outlawed, and far more numerous than any wrongful use of guns (even if you want to include suicides and gang-bangers or police removing hardened criminals from the pool), is the legitimate defensive use of guns by civilians. In over 90% of them, no shot is fired, and US DOJ numbers show that civilians who use guns in defense are less than 20% as likely as police to use them wrongly or cause undue harm.

Above all, what I never see in writings which are dubious about the civilian ownership of arms; What about the government itself establishing in courts that the police have no legal responsibility to come to our aid when attacked by criminals or madmen, and we have no recourse or appeal when we come to harm because (in the words of the court in one such case) "the best that can be said of the police is that they stood by and did nothing."
DeShaney v. Winnebago County, Gonzales v. Castle Rock, Warren v. District of Columbia, many more such cases.
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05:54 PM on 07/02/2010
And again, disingenuous to admit that the right to use lethal force in defense predates the constitution and is just, while the right to the best means of doing so, is suspect.

What about the police being universally respected and efficient? Never mind the phenomena of "contagious shooting", and no-knock raids resulting in deaths of innocents and rarely or never any change from the policies that make this sort of thing possible, never any adequate recompense for the damage the police do.
Never mind the police being another arm of the government monopoly on the use of force, and conducting unconstitutional door-to-door searches and seizures of property alongside the Army, never mind the government hanging onto and building up it's ability to spy and search without warrant, and sweep any of us up at any time without due process or habeus corpus, take us anywhere around the world and torture us and hold us indefinitely, when we haven't done any crimes.
Never mind our own government being the worst abuser of brute force around the globe, while we'd like to teach our children that it's better to talk over our differences than fight.
10:15 AM on 06/30/2010
There is no way to reasonably call the McDonald verdict an anomoly, nor is there evidence that "ever fewer citizens have guns". On the contrary, the examples of armed citizens using guns for lawful self defense abound, with more cases pilling up every week

http://www.thearmedcitizen.com/

Spitzer also neglects to mention the drop in crime over the last two decades has been accompanied with a mass legalization of lawful concealed carry. In the mid 80's only a few states had lawful CCW. Now 48 states do.

Lawful gun ownership and use has been a constant companion of our crime reduction. The McDonald verdict goes along with that very nicely.
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pcrudy
12:21 PM on 06/30/2010
I just finished the article and was going to make the same comments you made. Well done. That this twit seems to think that fewer citizens own guns and is unable to connect right to carry laws and the reduction in crime etc. is the kind of ignorance that should scare people.
Re the four cities that have the strictest gun control, i.e. Detroit, Chicago, DC and NY city, they 'own' about 20 per cent of all homicides committed in this country. However, I am afraid it is going to take another round of lawsuits before the good people of those cities can truly protect themselves and get their homicide rates under control.
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Lab Sharpei
09:55 AM on 06/30/2010
How in the world could the SC conclude in 1833 that the Bill of Rights does not apply to the states????
10:12 AM on 06/30/2010
Because at the time it did not. It was only after the passage of the 14th amendment that the bill of rights applied to the state. Before that it was only used on the federal government.
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Lab Sharpei
10:45 AM on 06/30/2010
This is contrary to what William Rawle, Appointed to US Attorney by George Washington, wrote in America's first difinitive commentaries on the US Constitution.

In, "The View of the Constitution" written in 1825, he writes:

"In the 2nd Amendment, it is declared....that the right of the people to keep and bear arms shall not be infringed. The prohibition is general. No clause in the Constitution could, by any rule of construction, be conceived to give the Congress a power to disarm the people. A flagrantly wicked attempt could only be made under some general pretense by a STATE LEGISLATURE. But if, in any blind pursuit of inordinate power, either the STATE or federal government should attempt it, this Amendment may be appealed to as a restraint on both".

I believe the SC in 1833 ruled incorrectly, and according to Rawle, who was with the Founders, knew exactly that the Bill of Rights applied to all citizens who live in the states...
08:40 AM on 06/30/2010
The contortions through which antigun zealots will go to try to argue that the 2nd Amendment doesn't mean what it says is truly remarkable. No matter what folks like this writer suggest, the majority of legal scholars--even liberal firebrands like Alan Dershowitz--agree that the 2nd protects an individual right to keep and bear arms. It isn't complicated. Heller did not reject precedent. The SCOTUS had avoided ruling definitively on the "individual right" issue. Now it has. And its ruling is binding precedent.
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Lab Sharpei
11:06 AM on 06/30/2010
Right on and fanned!
01:14 PM on 06/30/2010
Back atchya.
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OdinsEye
Korean-Latino cop and combat vet
09:19 PM on 06/29/2010
"the piecemeal incorporation process suggested, not all Bill of Rights protections were equally important. No one was beating down the doors of judicial chambers to incorporate the Third Amendment's protection against the quartering of troops in people's homes in peacetime, or the Seventh Amendment's right to common law suits "where the value in controversy shall exceed twenty dollars," or, for that matter, the Second Amendment's militia-based right to keep and bear arms -- a right rendered obsolete with the decline of old-style militia system. "


Actually it had nothing to do with importance. The court decided to incorporate only as cases before them. When has anyone had standing to challenge the 3rd Amendment due to state infringement? NEVER.

As for the Second, it is not militia based. The right to arms has never been based on militia service.
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Appleblossom
09:27 PM on 06/29/2010
You are incorrrect sir-Engblom v. Carey, 677 F.2d 957 (1982)
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mackbolan
Libertas inaestimabilis res est
09:35 PM on 06/29/2010
so the third has been incorporated....good....
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OdinsEye
Korean-Latino cop and combat vet
09:41 PM on 06/29/2010
Good catch, but since it never made it to the USSC, it still supports my assertion that no one with standing has challenged it in front of the USSC. And it refutes Spitzer's assertion about the 3rd having never been incorporated since the Second Circuit clearly stated that the Third is incorporated.
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mackbolan
Libertas inaestimabilis res est
09:06 PM on 06/29/2010
as i have pointed out on other threads...we had guns with us when we landed at plymouth rock...and we have carried them with us ever since and used them for every purpose for which a gun can be used..both good and bad....the supreme court has never denied that history and in fact with the macdonald ruling they simply acknowledged that fact....the meaning of the second amendment has never been in doubt except to the nanny staters.....

and when did the supreme court say that an american cannot defend their life with a gun....
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Rooster Coburn
Less Gov't + More Responsibility = A Better World
08:48 PM on 06/29/2010
"Instead, it's a right (admittedly limited) to civilian gun ownership, which means, quite simply, a right to civilian-controlled deadly force."

Damn right! That's what our Founders intended.
08:43 PM on 06/29/2010
The Constitution deals with militias in Article 1 section 40. The actual Second Amendment which was adopted three years later as part of a bill of rights necessarily deals with individual rights. The key word is regulated. In 1790 the word regulated also meant equipped. And, "A well equipped militia being necessary for the security of a free state, the right of the people to keep and bear arms... "makes perfect sense in today's lexicon. The meaning becomes clear. In the historical context, the British regulars marched out of Boston toward Concord that April of 1775, to seize the local militia's store of powder and shot. The whole revolution was touched off by an incident relating to the people bearing arms. It makes no sense that an amendment in the Bill of Rights was not intended to address those important individual concerns.
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01:56 PM on 07/01/2010
"The Constitution deals with militias in Article 1 section 40."

I believe you mean Article I, Section 8, Paragraphs 15-16. There is no Section 40 in Article I.
04:29 PM on 07/01/2010
Yes, you are right. My copy of the Constitution is indexed differently from yours.
08:24 PM on 06/29/2010
So the left doesn't beleive that of all the liberties that that Founding Fathers bestowed upon the ability and right to defend ones self was not one of them?
01:07 PM on 06/30/2010
The Founding Father bestowed nothing upon us, the Constitution and the Bill of Rights simply recognized the rights men have by simple fact of birth.
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02:58 PM on 06/29/2010
Mr. Spitzer post has led me on a search for the historical roots of "the right to bear arms." In European Feudalism it seems that all able males were required to bear arms. But when the lord of the manor called on them to repel invaders from the lord next door, they better come running, or else.

So, does that mean all able men and women today should be doing the same? We aren't in a feudal system but the concept is pretty clear to me.
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Dimensio
I just don't know what went wrong!
03:04 PM on 06/29/2010
You are correct. Should an invasion of the United States occur, firearm owners, such as myself, may be called upon to repel the invading forces.
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Appleblossom
09:03 PM on 06/29/2010
Because the US Army no longer has anything like tanks or surface to air missiles. Air Force also lost all their planes. And the bombs all were lost.

Nope, it is the civilian force made up with people with hand guns that can take out tanks, helicopters, fighter planes and all the other ordinance that modern militaries have.
08:13 PM on 06/29/2010
You seem to be trying to equate being a member if the unorganized militia (which, IIRC, all males of a certain age technically are) with conscription. I am convinced that were we actually invaded by someone, the military would have no trouble finding volunteers to go fight them. Now, fighting some pointless war in Afghanistan is a bit harder to sell.
02:44 PM on 06/29/2010
"Violence against the government is increasingly seen by some as noble"? According to who?
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Appleblossom
09:04 PM on 06/29/2010
People who hate Billy and Juan from down the street.
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JimInHouston
Arma virumque cano...
08:49 AM on 06/30/2010
O please be specific!
Berettasskeeter
For what we are about to receive, may we be truly
12:21 PM on 06/30/2010
And who are they? Have they said they "hate" Billy and Juan, or is this just your own bigotry speaking?
Semper fi
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02:36 PM on 06/29/2010
I don't want to buy your book. I just want to know if you are a tea bag partier or a half normal person. Half normal meaning a moderate centrist of the democrat or republican persuasion
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CanisLatrans
Progressive/2nd Amendment Jewish Iraq war vet.
01:51 PM on 06/29/2010
If "the right of the people to keep and bear arms" is applicable ONLY to the State Militias, then it stands to reason that the rights of the people to freedom of speech applies only to State Media outlets; and the right of the people to be secure from unreasonable search and seizure applies only to state employees on state property. And the right of the people to remain silent to avoid self-incrimination applie sonly to State employees as well. And the right of the people to a trial by a jury of their peers, again, only applies to State employees.

The "militia" at the time of writing was "every able-bodied man". We'd probably now regard that as "every able-bodied CITIZEN" to be inclusive of females.

I know a lot of people are afraid of guns or hate guns, and hate & fear their fellow citizens who own guns, but you can't apply a "special" interpretation of the 2nd Amendment without opening that can of worms on all of them.

The Supreme Court did agree that certain restrictions and requirements can still stand as Constitutional (like shouting "fire" in a theatre TECHNICALLY limits free speech, but is accepted as a reasonable restriction) so I'm sure some fine-tuning will be had. Requiring training is a good one, that I (as a gun owner) would see as an improvement regardless.