In 1834, the Tennessee Supreme Court revised the firearms provision in its state constitution on racial grounds: “the freemen of this State have a right to keep and to bear arms for their common defence” became “the free white men of this State have a right to keep and to bear arms for their common defence.”10 Supreme courts in nearby states followed suit in the years leading up to and during the US Civil War by proclaiming that gun rights extended only to white “citizens.”

