Best to re-read the decision in Miller. Bad Law never makes for good decisions. Simply put. Two defendants, one Miller, the other name escapes me at thew moment were arrested and charged with possession of the sawed off shotgun. They were convicted, but won on appeal to a federal lower court. Released from custody, they hauled ass as freed men. The US appealed to the SCOTUS. One of the defendants was dead and the others whereabouts unknown, so THEY WERE NOT REPRESENTED DURING PROCEEDINGS BEFORE SCOTUS. SCOTUS declared no evidence was presented to determine the efficacy of a sawed off shotgun in warfare or military use, so the conviction was re-instated.Sawed off shotguns were common in trench warfare as well as later by the Tunnel Rats in 'Nam. As noted in later cases, The Gun Control Act of 1934, because it infringed on an individuals right to keep and bear arms, actually had to be bad law. Automatic weapons and sawed off shotguns are used militarily, ergo, any citizen should be able to keep and bear those weapons. Pardon me if I don't get all sweaty palmed over an opinion in a blog in the New Yorker. No problem. As it defines what a militia is, it may have some bearing on your erroneous conclusion only militias can have firearms.