Throughout the 1960s, polls showed that between 50 and 60 percent of Americans favored an outright ban on handguns. Moreover, judicial opinion on the Second Amendment was considered “settled law,” meaning that all the legal precedents, most recently synthesized in U.S. v. Miller (1939), found that the right to bear arms in the Second Amendment was conditional upon service in the militia and therefore did not constitute a nearly unlimited individual right. When Chief Justice Warren Burger, a conservative appointed by Richard Nixon, was asked if the Second Amendment guaranteed open-ended access
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