This should serve as your periodic reminder that the case that Jeffrey Toobin lays out here — that the Second Amendment was never intended to protect an individual right — is an outlandish conspiracy theory that contradicts the text; the history; all of the contemporary commentary; the views of the drafters of the 14th Amendment, who incorporated it; and the actions of the states, almost all of which protected the individual right to keep and bear arms both before and after the drafting of the Second Amendment. It is an argument akin in nature and intent to the fraudulent work of the disgraced “historian” Michael Bellesiles, and those who peddle it should be just as ashamed of themselves as Bellesiles was eventually forced to be. The history here is clear and unequivocal, and it cannot be wished away on policy grounds.