text: Stephen Halbrook, a lawyer and Second Amendment analyst who successfully argued three firearms-related cases before the Supreme Court, concluded the majority's opinion in Heller "relied on text, history, and tradition." Halbrook asserted that the individual right to bear arms was not an invention of gun rights activists in the preceding few decades, but was in fact a textualist interpretation confirmed by the historical context of the Second Amendment. This included the English Declaration of Rights of 1689, as well as "post-ratification commentary, antebellum judicial opinions, Reconstruction legislation, and post-Civil War commentary."
  The Court's statement that the right secured by the Second Amendment is limited has been widely discussed by lower courts and the media. According to Justice John Paul Stevens, he was able to persuade Justice Anthony M. Kennedy to ask for “some important changes” to Justice Scalia's opinion, so that the final version of Heller “should not be taken to cast doubt” on the many gun laws existing in the United States.
  The decision in this case led to the Supreme Court Case New York State Rifle & Pistol Association, Inc. v. Bruen (2022) that ruled that the ability to carry a pistol in public was a constitutional right guaranteed by the Second Amendment.