interpretation by the courts. contrary to the reports pushed by the nra and other gun lobbying groups, for most of american history, the idea that the second amendment guaranteed unfettered personal gun ownership was a nonstarter. indeed, well into the 20th century, the supreme court repeatedly ruled that the second amendment applied only to gun ownership within the context of a state militia. supreme court justiceberger, appointed by richard nixon was asked about the nra idea of unlimited gun ownership under the second amendment in 1991. >> this has been the subject of one of the greatest pieces of fraud -- i repeat the word fraud -- that i have seen in my life. >> in between his condemnation of unrestricted firearm access