A Message from the President of Americans Against Gun Violence
December 5, 2021
On the morning of Tuesday, November 30, a day that had been declared, “Giving Tuesday,” I sent out a message to our supporters in which I posed the question, “Are you unknowingly contributing to ‘The Other Big Lie.’” The “Other Big Lie” to which I was referring was the fraudulent claim that the Second Amendment was intended to confer an individual right to own guns. I was prompted to send out the message by the fact that I was receiving numerous email appeals on “Giving Tuesday” for renewed contributions to gun violence prevention (GVP) organizations that either tacitly endorsed “The Other Big Lie” or that were silent about it. I also noted in my November 30 message that as a result of failing to confront “The Other Big Lie,” the limited measures that these other GVP organizations advocated fell into the category of what Joshua Sugarmann, Executive Director of the Violence Policy Center, has described as “nibbl[ing] around the edges of half-solutions and good intentions, dramatically out of sync with the reality of gun violence in America.”
I concluded my November 30 message by noting that despite numerous horrific mass shootings on school campuses across the United States, Americans Against Gun Violence remains the only U.S. GVP organization that openly advocates and is actively working toward overturning the Supreme Court’s rogue 2008 Heller decision, in which a narrow 5-4 majority of the Court endorsed “The Other Big Lie” by ruling for the first time in U.S. history that the Second Amendment confers any kind of individual right to own a gun unrelated to service in a “well regulated militia.” I also noted that Americans Against Gun Violence is also the only U.S. GVP organization that openly advocates and is actively working toward adopting stringent gun control laws in our country comparable to the laws in the other high income democratic countries of the world, including a complete ban on civilian ownership of handguns, comparable to the ban that Britain adopted following the mass shooting at the elementary school in Dunblane, Scotland in 1996.
I clicked on the “send” button for my November 30 message at 9:45 AM, PST (12:45 PM Michigan time), and the message was queued for delivery. The message was actually sent at 9:58 AM PST (12:58 PM Michigan Time). I learned later on the afternoon of November 30 that between the time that I clicked on the “send” button and the time that the “Other Big Lie” message went out, emergency responders in Oakland County, Michigan, began receiving 911 calls from Oxford High School where a mass shooting was in progress. By the time that law enforcement officers arrived and disarmed the shooter, a 15 year-old male student, three students had been shot and killed and seven other students and a teacher had been wounded. The following day, one of the wounded students died of the wounds he had sustained and two of the other wounded students remained in critical condition with gunshot wounds to the head, neck, and chest.
The Oxford High School mass shooting was the 29th shooting on a U.S. K-12 school campus so far this year. The gun homicide rate for all ages combined in the United States is “just” 25 times higher than the average gun homicide rate for the other high income democratic countries of the world, but the gun homicide rate for high school age youth in the United States is a staggering 82 times higher than the rate for their counterparts in other advanced democracies. American high school students legitimately fear getting shot and killed every day they go to school. If you don’t believe me, read the essays of our annual national high school essay contest winners that are posted on the High School Essay Contest page of our Americans Against Gun Violence website.
As is the case with most school shootings, the weapon used in the Oxford High School mass shooting was a handgun that the student brought from home. Initial reports indicated that the student’s father had legally purchased the handgun four days earlier. If the purchase was done like most other gun sales in our country, the father bought the gun after passing a rudimentary computerized instant background check to see if he was on a chronically incomplete database of persons who meet one or more limited criteria for being prohibited from purchasing a gun. If the father was like most other Americans who keep a handgun in the home, he acquired the gun in the mistaken belief that it would confer some net protective value, despite the overwhelming evidence that a gun in the home is far more likely to be used to kill, wound, or threaten household members than to protect them. And if the perpetrator’s father was like most other parents who keep guns in their homes, he would probably have underestimated the ease with which his son could gain access to the gun. (Information that has surfaced more recently about the Oxford High School shooting suggests, however, that in this case, the father, who, along with his wife, has been arrested and charged with being complicit in the mass shooting, may have actually purchased the handgun to give to his son.)
Prior to the Supreme Court’s rogue 2008 Heller decision, there was no constitutional right, Second Amendment or otherwise, for any individual person to own a handgun, or, for that matter, to own any other kind of a gun unrelated to service in a “well regulated militia.” The Second Amendment to the U.S. Constitution states, in its entirety:
A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.
In the 2008 Heller decision, though, a narrow 5-4 majority of the Court reversed over two centuries of prior legal precedent, including four previous Supreme Court opinions,  in ruling that Washington DC’s partial handgun ban violated the Second Amendment. In the most recent Second Amendment case prior to Heller, the 1980 Lewis decision, the Supreme Court had stated, quoting from its 1939 Miller decision:
[T]he Second Amendment guarantees no right to keep and bear a firearm that does not have “some reasonable relationship to the preservation or efficiency of a well regulated militia.”
While I may be the first person to describe the Heller decision as an outright lie, others have intimated as much. In 1991, the late Supreme Court Chief Justice Warren Burger, speaking on the PBS News Hour, described the gun lobby’s misrepresentation of the Second Amendment - the same misrepresentation that the five justices in the majority endorsed in their 2008 Heller decision - as ”[O]ne of the greatest pieces of fraud - I repeat the word, ‘fraud,’ - on the American public by special interest groups that I have ever seen in my lifetime.” In his autobiography, the late Supreme Court Justice John Paul Stevens, who wrote a dissenting opinion in Heller, made reference to Chief Justice Burger’s prior comment concerning the fraudulent misrepresentation of the Second Amendment, and he added that the Heller decision was “unquestionably the most clearly incorrect decision that the Court announced” during his own 35 year tenure as a Supreme Court justice. Other respected authorities have described the Heller decision as “gun rights propaganda passing as scholarship” and as “evidence of the ability of well-staffed courts to produce snow jobs.”
I’ve discussed specific examples of some of the more egregious misrepresentations of historical facts; quotations taken out of context; circular reasoning; and nonsensical and bombastic rhetoric in the Heller majority opinion in other Americans Against Gun Violence president’s messages. Rather than repeating these examples here, I’ll refer you to the search icon on this website (the magnifying glass on the red header bar) if you’re interested in reading more on this topic. I will re-emphasize in this message, though, that it’s no exaggeration to say that the claim that the Second Amendment was intended to confer an individual right to own guns is every bit as big a lie as the “Big Lie” that Donald Trump won the 2020 presidential election. Similarly, endorsing the claim - as some other prominent GVP organizations do - that the Second Amendment confers an individual right to own guns, but with the caveat that this right is not unlimited, is equivalent to stating that Donald Trump won the 2020 presidential election, but that his power, as he continues to hold the office of President of the United States, is not unlimited. It is also no exaggeration to state that in creating a constitutional obstacle, where none previously existed, to the adoption of stringent gun control laws in the United States comparable to the laws in other high income democratic countries – countries in which mass shootings, including shootings on school campuses, occur rarely, if ever, and in which the rate of gun related deaths is, on average, one tenth the rate in our country – the Supreme Court’s endorsement of “The Other Big Lie” in the Heller decision is literally a death sentence for tens of thousands of Americans annually.
New appeals for donations from other GVP organizations to which I’ve contributed in the past kept popping up in my inbox on the afternoon and evening of “Giving Tuesday.” Some of the appeals included heart-wrenching testimonials from individuals who had lost loved ones to gun violence, including messages from parents of victims of the 2012 Sandy Hook Elementary School mass shooting. A few of the appeals mentioned the Oxford High School mass shooting that had occurred earlier in the day as a reason for even greater urgency for me to make a donation.
But while the appeals were big on emotion, big on “Stop the NRA” banners, and big on “DONATE NOW” buttons, they were universally devoid of content concerning how, specifically, the organizations soliciting the donations intended to stop our country’s shameful epidemic of gun violence. I know from years of trying to work with these organizations that the measures that they have advocated in recent years are the same old “nibbl[ing] around the edges of half-measures and good intentions” that Josh Sugarmann criticized two decades ago. I went to their websites on “Giving Tuesday,” though, to see if anything had changed, and I found that it hadn’t, with one exception. One of the best-known organizations, founded 20 years ago, had previously stated that its goal was “cutting gun deaths in half by 2025.” This goal had been removed from the organization’s website, and for obvious reasons. From 2001, the year the organization was founded, through 2019, the most recent year for which data are available from the CDC, the annual number of gun related deaths in the United States has risen from 29,573 to 39,707, and unofficial data indicate that the annual number gun related deaths hit a record high of more than 44,000 in 2020. Rather than “cutting gun deaths in half,” this organization has cut its stated goal in half. The organization’s website now lists “Reduce gun violence by 25% by 2025” as its mission. If we continue to “nibble around the edges of half-measures and good intentions,” though, as this organization and other like it advocate, we’ll be lucky if the annual number of gun related deaths in our country doesn’t reach 50,000 by 2025, and we shouldn’t be the least bit surprised when the next horrific mass shooting occurs.
Having tried to get other GVP organizations to join us in filing amicus curiae (friend of the court) briefs in important Second Amendment cases, I was also aware, as appeals for donations kept popping up in my inbox on “Giving Tuesday,” that they’ve all either been silent on subject of “The Other Big Lie” or have actually endorsed it, tacitly at least, including in the most recent Supreme Court case of the New York State Rifle and Pistol Association v. Bruen et al, a case that the Court is currently pondering after hearing oral arguments on November 3. This case, in which the gun lobby is claiming that New York State’s regulations concerning carrying loaded handguns in public violate the Second Amendment, is based entirely upon “The Other Big Lie” endorsed by the Court in its 2008 Heller decision. More than 50 amicus briefs were filed by the gun lobby and gun lobby sympathizers in this case. All of these briefs wholeheartedly endorsed “The Other Big Lie” and called on the Supreme Court to expand the right it created in Heller from a right to keep a handgun in the home to also include a right to carry a concealed handgun in public. Thirty-six other amicus briefs were filed in support of New York’s handgun laws on behalf of 84 organizations, 13 cities, 18 states, and more than 600 individuals, including 152 members of Congress. But only one of these amicus briefs – the one we filed on behalf of Americans Against Gun Violence – noted that the Heller decision was based on an interpretation of the Second Amendment that the late Supreme Court Chief Justice Warren Burger had called, “[One] of the greatest pieces of fraud – I repeat the word, ‘fraud,’ – on the American public by special interest groups that I have ever seen in my lifetime.” And with the exception of one brief filed by an individual attorney in Washington State, no brief other than ours calls on the Supreme Court to not only rule that New York State’s handgun laws are not unconstitutional, but to take the opportunity of the NYSRPA v. Bruen case to overturn the Heller decision.
The briefs filed by other GVP organizations in NYSRPA v. Bruen, as in other recent Second Amendment cases, are either silent on the subject of “The Other Big Lie” or tacitly endorse it. For example, the brief submitted by the organization whose goal had been to cut gun deaths in half by 2025 stated, under the heading, “Heller Reaffirmed Longstanding Guardrails on the Second Amendment:”
In Heller, this Court made clear that “[l]ike most rights, the right secured by the Second Amendment is not unlimited.”
As I’ve noted above, stating that the Heller decision “reaffirmed” that the Second Amendment confers individual right to own guns, but that this right “is not unlimited,” is comparable to stating that Donald Trump won the 2020 presidential election, but that his power during his second term “is not unlimited.” Furthermore, the heading, “Heller Reaffirmed Longstanding Guardrails on the Second Amendment,” is comparable to a heading that states, “Trump Reaffirmed Longstanding Guardrails on Free and Fair Elections.”
Another high profile GVP organization filed an amicus brief in the NYSRPA v. Bruen case in which it endorsed a corollary to “The Other Big Lie,” the lie that the Second Amendment was intended to confer an individual right to own guns, but only for the purpose of self-defense. In its amicus brief, this organization wrote:
As Heller observed, self-defense is “the central component” and “core lawful purpose” of the Second Amendment right.
As the Second Amendment itself states, though, and as the Supreme Court and virtually every lower court had ruled prior to the rogue 2008 Heller decision, the Second Amendment was intended to confer a collective right of the people of the states to maintain “a well regulated militia.” There is nothing in the text or the history of the Second Amendment that even faintly suggests that the Amendment was intended to confer an individual right to own firearms for the purpose of personal self-defense. Moreover, the amicus brief filed by this organization, like the Heller majority opinion, fails to acknowledge the fact that far from being weapons of “self-defense,” there is overwhelming evidence that guns in the homes and in the communities of honest, law-abiding people are far more likely to be used to kill, injure, or intimidate them than to protect them.
The organization that was founded by parents of the 20 first grade children who were killed in the 2012 Sandy Hook Elementary School mass shooting didn’t file an amicus brief at all in the NYSRPA v. Bruen case, although on its website, under the heading, “Donate to Protect Children from Gun Violence,” the organization states, “We’re doing everything we can to protect more children from school shootings, violence, and other harmful acts.” The email I received from this organization on “Giving Tuesday” asked for a contribution to help meet the organization’s “Giving Tuesday” fundraising goal of $755,000. The financial report on the organization’s website indicates that its annual budget is over $12 million. This organization doesn’t advocate any gun control measure, though, that could reasonably be expected to have prevented the Sandy Hook massacre.
I’ve talked personally with some of the Sandy Hook parents, I’ve met and spoken with Gabby Giffords briefly; I’ve known some of the founders and leaders of other prominent GVP organizations on a first name basis; I’ve worked with some of these individuals for decades; I’ve contributed to their organizations in the past; and I continue to confer with some of them regularly. Gabby Giffords has shown extraordinary courage and resilience in just going on living, much less staying active in the arena of gun violence prevention, following a devastating gunshot wound to the head that she herself suffered in a mass shooting in 2011. Many of the other founders of GVP organizations, like the Sandy Hook parents, have suffered tragic losses of loved ones to gun violence. These are fine, intelligent, well-meaning people. Why don’t they join Americans Against Gun Violence in openly advocating and actively working toward overturning the Heller decision and adopting stringent gun control laws in the United States comparable to the laws that have long been in effect in the other high income democratic countries of the world? I’m not entirely sure. One reason may be that they’ve become victims of a form of “Stockholm Syndrome,” also known as “capture bonding.” They may have been held captive, in a psychological sense, so long by the gun lobby that they’ve come to unconsciously sympathize with it. Another reason may be the phenomenon of “anchoring,” – the powerful tendency of human beings to stick with their initial approach to a problem despite the accumulation of extensive evidence that this approach is failing.
To be candid, during the decades that I’ve been working on the gun violence prevention issue, I’ve also encountered individuals who seem to me to be motivated more by lining their own pockets and gratifying their own egos than by actually reducing rates of gun related deaths and injuries. In my experience, these kinds of individuals have been in the minority, although they seem to be disproportionately represented in positions of power in some of the other GVP organizations.
To make a long story short, I’ve stopped contributing to other GVP organizations, not because of any antipathy I have toward individuals who are the founders and members of these organizations, but because I’ve come to the realization that the greatest obstacle that we at Americans Against Gun Violence face in getting the Heller decision overturned and in achieving the adoption of the kinds of stringent gun control laws necessary to stop our country’s shameful epidemic of gun violence may not be the gun lobby. The greatest obstacle may well be the other GVP organizations that either tacitly endorse “The Other Big Lie” or that are silent about it; and that promote the false notion that we can substantially reduce rates of gun related deaths and injuries in our country without overturning the Heller decision and without adopting stringent gun control laws in the United States comparable to the laws in other high income democratic countries.
I’m sure that few if any people on our contact list (other than the gun lobby moles who occasionally reveal themselves with obscene responses to my president’s messages) believe any of the gun lobby’s propaganda. I know from individual conversations with a number of our supporters, though, that many people who are seriously concerned about our country’s gun violence epidemic and who want to help stop it do believe it when other GVP organizations make statements like the one in the brochure I was handed the last time I attended one of these organization’s annual dinners. The brochure was entitled, Ten Myths About Gun Violence in America, and it stated, under the heading, “Myth: New Gun Laws Are a Slippery Slope to Confiscation:”
…the Supreme Court affirmed [in Heller] the right to keep a gun for self-defense. Nevermind that no serious organization advocates for mass firearm confiscation or that collecting America’s 357 million firearms would be a logistical impossibility. In reality, smart gun laws are about saving lives and ensuring responsible gun ownership, not taking away guns.
First of all, as I’ve noted above, the Heller decision didn’t “affirm” a right to keep a gun for self-defense; it created a constitutional right to keep a handgun in the home, where no such right previously existed. The Heller decision, like this GVP organization’s brochure, also promoted the deadly myth that a gun in the home confers some net protective value. Secondly, Americans Against Gun Violence is a serious organization. We don’t advocate “confiscating” massive numbers of firearms. We do advocate completely banning civilian ownership of all automatic and semi-automatic long guns (including so-called “assault rifles”) and requiring individuals who own those kinds of guns to surrender them in return for monetary compensation, just as Great Britain, Australia, and New Zealand all promptly did after mass shootings committed with semi-automatic long guns in Hungerford, England in 1987; in Port Arthur, Australia in 1996; and in Christchurch, New Zealand in 2019. We also advocate banning civilian ownership of handguns, as Britain promptly did after the 1996 Dunblane Primary School massacre, which was committed with handguns. And finally, even if we advocated completely banning civilian ownership of all firearms, collecting and scrapping every one of the more than 400 million guns that are now estimated to be in private hands in the United States would not be a “logistical impossibility.” Every year, approximately 12 million automobiles are scrapped in our country, and scrapping a car is logistically far more difficult than scrapping a gun.
Rather than going into detail in this message concerning why the limited measures advocated by other GVP organizations are minimally, if at all, effective in reducing rates of gun related deaths and injuries in the short term, and why focusing on such measures is counter-effective in working toward definitive measures in the long term, I’m going to rely on the principle that a picture (or in this case, a graph) is worth a thousand words. As the graph below demonstrates, there is a direct relationship at the international level between rates of gun related deaths and rates of private gun ownership, with the United States being an extreme outlier in both categories. Any organization that claims that we can significantly reduce rates of gun related deaths in the United States to levels anywhere comparable to the rates in the other high income democratic countries of the world without drastically reducing the pool of privately owned guns is claiming that we can move the lonely circle representing our country in the upper right hand corner of the graph far to the left on the annual gun death rate axis without also moving it down on the rate of gun ownership axis. No other high income democratic country has been able to achieve such a feat, and it’s chimerical to believe that the United States could do so.
Graph of Rates of Gun Related Deaths versus Rates of Private Gun Ownership in the United States and 16 Other High Income Democratic Countries
Legend: Annual rates of gun deaths are plotted against estimated per capita gun ownership for the United States and 16 other high income democratic countries, all represented as circles. (Because of overlap, there appear to be fewer than 16 circles representing other high income democratic countries.) The line is a computer generated best fit line. Data used to construct the graph were taken from the most recently available data posted on the website, GunPolicy.org, hosted by the University of Sydney School of Public Health. In cases in which GunPolicy.org listed a range of per capita gun ownership estimates for a given country, the mean of the highest and lowest estimates was used. The 16 other high income democratic countries represented on the graph are, in alphabetical order, Australia, Belgium, Canada, Denmark, Finland, France, Germany, Italy, Japan, New Zealand, Norway, Sweden, Switzerland, and the United Kingdom.
In conclusion, I’m not going to recommend that you never contribute again to another GVP organization other than Americans Against Gun Violence. I do recommend, however, that before you contribute to another organization, you first view my November 7 interview with Dr. Michael North of Scotland The interview was conducted via Zoom and is now posted on YouTube.
Dr. North lost his five year-old daughter, Sophie, in the 1996 mass shooting at the elementary school in Dunblane, Scotland. As noted above, Great Britain already had a ban on civilian ownership of automatic and semi-automatic long guns, including so-called “assault rifles,” but the shooter in the Dunblane Primary School massacre used semi-automatic handguns that he legally owned to murder Sophie, 15 of her classmates, and their teacher, and to wound 12 other students and three other teachers before killing himself. In the November 7 interview, Dr. North describes eloquently and humbly how he and the other grieving Dunblane parents decided that nothing short of a complete ban on civilian ownership of handguns would suffice to prevent other parents and children from having to endure the same horror that they and their children experienced. Despite what initially seemed to be insurmountable obstacles, including the British gun lobby, callus politicians, and even insensitive remarks by the Queen of England, Dr. North and his colleagues succeeded in getting a complete handgun ban passed within less than two years of the Dunblane massacre. Since the ban was enacted in 1998, there have been no further school shootings in Britain, and the overall rate of gun related deaths in the UK is currently 1/60th the rate in the United States.
In the November 7 interview, Dr. North also talks about being invited to participate in a summit hosted by the Johns Hopkins School of Public Health following the 2012 Sandy Hook Elementary School massacre and how his American counterparts discounted the relevance of the success that he and his colleagues had achieved in Britain and that two Australian participants had achieved in their country to the subject of preventing gun violence in the United States. The American’s dismissal of the relevance of the input from the three “foreigners” was based on what Dr. North describes in the November 7 interview as “the elephant in the room” – and what I call, “The Other Big Lie” – namely, the claim, unchallenged by the American participants in the conference, that the Second Amendment confers an individual right to own guns. (Dr. North and the two Australian participants, Rebecca Peters and Philip Alpers, all wrote lucid chapters in the compendium, Reducing Gun Violence in America: Informing Policy with Evidence and Analysis, that came out of the Johns Hopkins summit. The chapters in the compendium written by American authors all fall into the category of “nibbling around the edges of half-measures and good intentions,” and the chapter in the compendium concerning the Second Amendment wholeheartedly endorses “The Other Big Lie.”)
After watching the November interview with Mick North, and before contributing to other GVP organizations, I’ll ask you to again consider the question, "Are you contributing to 'The Other Big Lie?'” I’ll also ask you to consider whether supporting the limited measures advocated by these other GVP organizations will actually have a significant impact in reducing rates of gun related deaths and injuries in the United States, or whether prioritizing the limited measures they advocate may actually delay the adoption of the kind of stringent gun control measures necessary to end our country’s shameful epidemic of gun violence. And if you have questions about the effectiveness of these other GVP organizations, before contributing to them, I suggest that you ask them yourself why they don’t join Americans Against Gun Violence in openly advocating and actively working toward overturning the Heller decision and adopting stringent gun control laws in the United States comparable to the laws in other high income democratic countries.
Finally, I’d like to thank you for supporting Americans Against Gun Violence, and I’d like to assure you that we will never allow “The Other Big Lie,” no matter how many Supreme Court justices or other organizations endorse it, to deter us from working tirelessly to protect our children and our youth from the threat of being gunned down every time they set foot on a school campus.
Bill Durston, M.D.
President, Americans Against Gun Violence
Note: Dr. Durston is a board-certified emergency physician and a former expert marksman in the United States Marine Corps, and a combat veteran of the Vietnam War, decorated for “courage under fire.”
 Josh Sugarmann, Every Handgun Is Aimed at You: The Case for Banning Handguns (New Press, 2001), 181.
 District of Columbia v. Heller, 554 US (Supreme Court 2008).
 Michael J. North, “Gun Control in Great Britain after the Dunblane Shootings,” in Reducing Gun Violence in America: Informing Policy with Evidence and Analysis (Baltimore: The Johns Hopkins University Press, 2013), 185–93.
 Livia Albeck-Ripka, “What We Know About the Michigan High School Shooting,” The New York Times, December 1, 2021, sec. U.S., https://www.nytimes.com/2021/12/01/us/oxford-school-shooting-michigan.html.
 “School Shootings This Year: How Many and Where,” Education Week, March 1, 2021, https://www.edweek.org/leadership/school-shootings-this-year-how-many-and-where/2021/03.
 Erin Grinshteyn and David Hemenway, “Violent Death Rates: The US Compared with Other High-Income OECD Countries, 2010,” The American Journal of Medicine 129, no. 3 (March 1, 2016): 266–73, https://doi.org/10.1016/j.amjmed.2015.10.025.
 Ashish P. Thakrar et al., “Child Mortality In The US And 19 OECD Comparator Nations: A 50-Year Time-Trend Analysis,” Health Affairs 37, no. 1 (January 2018): 140–49, https://doi.org/10.1377/hlthaff.2017.0767.
 Albeck-Ripka, “What We Know About the Michigan High School Shooting”; Tawnell D. Hobbs, “Most Guns Used in School Shootings Come From Home,” Wall Street Journal, April 5, 2018, sec. US, https://www.wsj.com/articles/in-school-shootings-most-guns-come-from-home-1522920600.
 Robert J. Blendon, John T. Young, and David Hemenway, “The American Public and the Gun Control Debate,” Journal of the American Medical Association 275, no. 22 (June 12, 1996): 1719–22.
 See, for example: Arthur L. Kellermann and Donald T. Reay, “Protection or Peril? An Analysis of Firearm-Related Deaths in the Home,” New England Journal of Medicine 314, no. 24 (June 12, 1986): 1557–60, https://doi.org/10.1056/NEJM198606123142406; Arthur L. Kellermann et al., “Injuries and Deaths Due to Firearms in the Home,” Journal of Trauma and Acute Care Surgery 45, no. 2 (1998): 263–67; Deborah Azrael and David Hemenway, “‘In the Safety of Your Own Home’: Results from a National Survey on Gun Use at Home,” Social Science & Medicine 50, no. 2 (January 2000): 285–91.
 Miranda Hester, “Parents May Underestimate Teen’s Access to Guns in the Home,” Contemporary Pediatrics, March 17, 2021, https://www.contemporarypediatrics.com/view/parents-may-underestimate-teen-s-access-to-guns-in-the-home.
 Jack Healy, “Behind the Charges Faced by the Parents of the Michigan Shooting Suspect,” The New York Times, December 3, 2021, sec. U.S., https://www.nytimes.com/2021/12/03/us/crumbley-parents-charged-michigan-shooting.html.
 Heller, 554 US.
 United States v. Cruikshank, 92 US 542 (Supreme Court 1876); Presser v. Illinois, 116 US (Supreme Court 1886); U.S. v. Miller, 307 U.S. 174 (1939) (n.d.); Lewis v. United States, No. 55 (U.S. 1980).
 Lewis, 445 at 65n8.
 Warren Burger, PBS News Hour, December 16, 1991, c.
 John Paul Stevens, The Making of a Justice: Reflections on My First 94 Years (New York: Little, Brown, 2019), 483.
 Stevens, 482.
 Saul Cornell, “Originalism on Trial: The Use and Abuse of History in District of Columbia v. Heller,” Ohio State Law Journal 69 (2008): 629.
 Richard Posner, “In Defense of Looseness,” The New Republic 239, no. 3 (August 27, 2008): 35.
 Grinshteyn and Hemenway, “Violent Death Rates.”
 Sugarmann, Every Handgun Is Aimed at You, 181.
 “About Brady | Brady Campaign to Prevent Gun Violence,” accessed October 3, 2016, http://www.bradycampaign.org/about-brady.
 “Fatal Injury Data | WISQARS | Injury Center | CDC,” Centers for Disease Control and Prevention, accessed July 1, 2021, http://www.cdc.gov/injury/wisqars/fatal.html.
 “Past Summary Ledgers | Gun Violence Archive,” accessed July 1, 2021, https://www.gunviolencearchive.org/past-tolls.
 “United Against Gun Violence,” Brady, accessed December 5, 2021, http://www.bradyunited.org.
 New York State Rifle and Pistol Association, Inc, et al v. Bruen, et al, No. 20-843 (n.d.).
 Burger, Warren Burger on the 2nd Amendment.
 Brief for Brady New York State Rifle and Pistol Association, Inc, et al v. Bruen, et al.
 Brief of Giffords Law Center to Prevent Gun Violence New York State Rifle and Pistol Association, Inc, et al v. Bruen, et al at 6.
 “Donate to Help Protect Children From Gun Violence,” Sandy Hook Promise, accessed December 1, 2021, https://takeaction.sandyhookpromise.org/a/foundation?source=a_google_d2dever2017_br&utm_source=google&utm_medium=cpc&utm_campaign=grant&gclid=Cj0KCQiA15yNBhDTARIsAGnwe0XR08rU0ET8nPrhj1PzONEXOophASoGGBRAt7rf7h4GP1649BR_bmUaAntiEALw_wcB.
 Marc Lacey and David M. Herszenhorn, “Representative Gabrielle Giffords and 18 Shot Near Tucson,” The New York Times, January 8, 2011, http://www.nytimes.com/2011/01/09/us/politics/09giffords.html.
 Christopher Klein, “The Birth of ‘Stockholm Syndrome,’ 40 Years Ago - History in the Headlines,” HISTORY.com, August 23, 2013, http://www.history.com/news/stockholm-syndrome.
 Adrian Furnham and Hua Chu Boo, “A Literature Review of the Anchoring Effect,” The Journal of Socio-Economics 40, no. 1 (February 1, 2011): 35–42, https://doi.org/10.1016/j.socec.2010.10.008.
 “10 Myths about Gun Violence in America” (Law Center to Prevent Gun Violence), accessed July 11, 2017, https://smartgunlaws.org/wp-content/uploads/2012/05/Ten_Myths.pdf This brochure was deleted from the Giffords Law Center website after Dr. Durston sent the executive director, Robyn Thomas, a letter expressing his concerns about it, although Ms. Thomas never responded to Dr. Durston.
 North, “Gun Control in Great Britain after the Dunblane Shootings.”
 Rebecca Peters, “Rational Firearm Regulation: Evidence-Based Gun Laws in Australia,” in Reducing Gun Violence in America: Informing Policy with Evidence and Analysis (Baltimore: The Johns Hopkins University Press, 2013), 195–204; Joel Negin et al., “Australian Firearm Regulation at 25-Successes, Ongoing Challenges, and Lessons for the World,” New England Journal of Medicine 384, no. 17 (2021): 1581–83.
 “2019 Firearm Law Changes (Arms Amendment Bill 2),” New Zealand Police, accessed August 27, 2020, https://www.police.govt.nz/advice-services/firearms-and-safety/2019-firearm-law-changes-arms-amendment-bill-2.
 “Compare the United States – Rate of Civilian Firearm Possession per 100 Population,” GunPolicy.org, accessed September 18, 2016, http://www.gunpolicy.org/firearms/compare/194/rate_of_civilian_firearm_possession/10,280,31.
 Rick LeBlanc, “Car Recycling Facts and Figures,” The Balance, accessed July 11, 2017, https://www.thebalance.com/auto-recycling-facts-and-figures-2877933.
 North, “Gun Control in Great Britain after the Dunblane Shootings.”
 “Gun Law and Policy: Firearms and Armed Violence, Country by Country,” GunPolicy.org, accessed July 1, 2021, http://www.gunpolicy.org/.
 North, “Gun Control in Great Britain after the Dunblane Shootings”; Peters, “Rational Firearm Regulation: Evidence-Based Gun Laws in Australia”; Philip Alpers, “The Big Melt: How One Democracy Changed after Scrapping a Third of Its Firearms,” in Reducing Gun Violence in America: Informing Policy with Evidence and Analysis (Baltimore: The Johns Hopkins University Press, 2013), 205–11.
 Lawrence E. Rosenthal and Adam Winkler, “The Scope of Regulatory Authority under the Second Amendment,” in Reducing Gun Violence in America: Informing Policy with Evidence and Analysis (Baltimore: The Johns Hopkins University Press, 2012), 225–36.