United States v. Miller

In 1939 the U.S. Supreme Court heard the case United States v. Miller, ruling that through the National Firearms Act of 1934, Congress could regulate the interstate selling of a short barrel shotgun. The court stated that there was no evidence that a sawed off shotgun “has some reasonable relationship to the preservation or efficiency of a well regulated militia,” and thus “we cannot say that the Second Amendment guarantees the right to keep and bear such an instrument.”