text: The Breyer dissent also objected to the "common use" distinction used by the majority to distinguish handguns from machine guns: "But what sense does this approach make? According to the majority's reasoning, if Congress and the States lift restrictions on the possession and use of machineguns, and people buy machineguns to protect their homes, the Court will have to reverse course and find that the Second Amendment does, in fact, protect the individual self-defense-related right to possess a machine-gun...There is no basis for believing that the Framers intended such circular reasoning."
  Non-party involvement
  National Rifle Association (NRA)
  Attorney Alan Gura, in a 2003 filing, used the term "sham litigation" to describe the NRA's attempts to have Parker (aka Heller) consolidated with its own case challenging the D.C. law. Gura also stated that "the NRA was adamant about not wanting the Supreme Court to hear the case". These concerns were based on NRA lawyers' assessment that the justices at the time the case was filed might reach an unfavorable decision. Cato Institute senior fellow Robert Levy, co-counsel to the Parker plaintiffs, has stated that the Parker plaintiffs "faced repeated attempts by the NRA to derail the litigation." He also stated that "The N.R.A.'s interference in this process set us back and almost killed the case. It was a very acrimonious relationship."