Stephen P. Halbrook’s Confused Defense of Bruen’s Novel Interpretive Rule


Stephen P. Halbrook is a giant in the field of Second Amendment studies, and I doubt that there is anyone from whom I’ve learned more about the history of the right to keep and bear arms. I was therefore surprised to find many technical errors in his article, Text-and-History or Means-End Scrutiny? A Response to Professor Nelson Lund’s Critique of Bruen. Halbrook is also a very zealous and tenacious advocate for gun rights, and I can’t help wondering whether his zeal in defense of the Court may have obscured his scholarly vision.