How John Enos Interprets the Second Amendment Through Supreme Court Rulings

The Second Amendment to the U.S. Constitution—“the right of the people to keep and bear Arms, shall not be infringed”—has been one of the most hotly debated clauses in American law. In his landmark work, The Right to Keep and Bear Arms, John Enos offers a meticulously researched interpretation grounded in constitutional originalism and an analysis of key Supreme Court rulings. Enos explores how judicial decisions have shaped, refined, and sometimes distorted the meaning of the Second Amendment. His approach is both scholarly and accessible, offering a compelling narrative on how legal interpretation affects everyday rights.

Anchoring Interpretation in Originalism

At the heart of Enos’s analysis is a firm commitment to originalism. He believes that constitutional interpretation must stay true to the text’s original public meaning. Enos argues that when the Second Amendment was ratified in 1791, its language reflected a clear intent: citizens had a right to possess arms, not only for self-defense but also as a check against government tyranny.

John Enos aligns his perspective with Justice Antonin Scalia’s majority opinion in District of Columbia v. Heller (2008), a watershed moment in Second Amendment jurisprudence. In Heller, the Court ruled that the Second Amendment protects an individual’s right to possess a firearm, unconnected to militia service. Enos points out that Scalia’s originalist reasoning in this case validated a view long held by gun rights advocates. Enos further notes that Heller emphasized the historical context of the amendment—something Enos repeatedly stresses as central to understanding its true meaning.

Founders’ Vision and Judicial Interpretation

Enos maintains that any faithful reading of the Second Amendment must begin with the Founders’ intentions. He delves into writings by James Madison, George Mason, and other framers who viewed an armed populace as essential to liberty. According to Enos, early legal commentaries by figures like St. George Tucker and William Rawle reflect an unambiguous recognition of an individual right.

However, Enos also critiques how later courts strayed from this vision. Before Heller, the most influential Supreme Court case on the Second Amendment was United States v. Miller (1939). In that case, the Court upheld restrictions on certain types of firearms, interpreting the amendment through a collective rights lens—tied primarily to militia service. Enos argues that Miller misunderstood the historical role of militias, which, during the Founding era, were composed of ordinary citizens expected to supply their own arms.

He describes how the Court’s decision in Miller laid the groundwork for decades of judicial ambiguity. Lower courts leaned heavily on its militia-focused language, enabling laws that, in Enos’s view, violated the constitutional guarantee. It wasn’t until Heller that the Court decisively returned to an individual-rights interpretation, correcting what Enos calls “decades of judicial misdirection.”

Expansion of Rights in McDonald v. Chicago

John Enos devotes significant analysis to the 2010 case the Fourteenth Amendment. He sees this ruling as a natural extension of Heller, affirming that the right to bear arms is not limited to federal jurisdictions.

In The Right to Keep and Bear Arms Book Overview, Enos explains that McDonald established the Second Amendment as a fundamental right, comparable to freedom of speech or religion. This was a significant development, as it prevented states and municipalities from enacting draconian gun control measures without constitutional scrutiny. For Enos, McDonald marks the Second Amendment’s full constitutional maturity: no longer a dormant clause, but a fully recognized right with the same protections as other parts of the Bill of Rights.

He further emphasizes that McDonald was built on a robust originalist foundation. Justice Alito’s majority opinion surveyed 18th- and 19th-century understandings of the right to bear arms and concluded that it was “deeply rooted in the nation’s history and tradition.” Enos considers this historical grounding essential for preserving constitutional integrity and resisting politically motivated reinterpretations.

Reaffirming Rights New York State Rifle & Pistol Association v. Bruen

One of the most recent and significant cases discussed by Enos is New York State Rifle & Pistol Association v. Bruen (2022). This case invalidated a New York law requiring applicants to show “proper cause” for carrying concealed handguns in public. The Court ruled that such restrictions violate the Second Amendment because they do not align with the nation’s historical tradition of firearm regulation.

Enos praises the Bruen decision as a reaffirmation of the principles outlined in Heller and McDonald. He argues that the Court, by using a historical test rather than a policy-based one, anchored its ruling in constitutional fidelity. The decision, he believes, sends a clear message to lower courts: modern interpretations must be rooted in historical precedent, not shifting societal standards.

Historical Memory and Public Perception

A critical dimension of Enos’s work is his emphasis on public memory and historical literacy. He warns that popular misunderstandings of the Second Amendment—fueled by media narratives and educational gaps—have led to confusion about its scope. Enos argues that many citizens and lawmakers alike conflate the right to bear arms with gun violence or public safety concerns. While he does not dismiss those concerns, he insists they should not dictate constitutional interpretation.

Enos makes the case that rights are not subject to popularity or political expediency. The Constitution, he notes, was designed to limit government power and safeguard individual liberties—even when those liberties are controversial. By contextualizing Supreme Court rulings within a broader historical and philosophical framework, Enos helps readers see how the judiciary plays a central role in defending those liberties.

Call to Constitutional Literacy

Enos closes his book with a compelling call for greater civic education. He believes that many of the legal battles over the Second Amendment stem from a widespread ignorance of constitutional principles. By tracing the judicial journey from Miller to Heller, McDonald, and Bruen, Enos provides a roadmap for understanding not just the Second Amendment, but the nature of constitutional rights themselves.

He urges readers to engage with legal texts, historical documents, and court decisions directly. In doing so, citizens can better advocate for their rights and hold government accountable. Enos sees this educational mission as inseparable from the fight for liberty. If Americans are to preserve the freedoms secured by the Constitution, he argues, they must first understand them.

Conclusion

In The Right to Keep and Bear Arms,” John Enos offers a powerful interpretation of the Second Amendment, grounded in originalist philosophy and informed by pivotal Supreme Court rulings. By examining cases like Heller, McDonald, and Bruen, Enos demonstrates how the judiciary has both hindered and upheld the right to bear arms. His work is a call to historical awareness, constitutional literacy, and vigilant protection of individual freedoms.