Stephen P. Halbrook is a giant in the field of Second Amendment studies, and I doubt that there is anyone from whom I’ve learned more about the history of the right to keep and bear arms. I was therefore surprised to find numerous fallacious arguments and technical errors in his response to my analysis of the Court’s latest Second Amendment decision: Text-and-History or Means-End Scrutiny? A Response to Professor Nelson Lund’s Critique of Bruen. Halbrook is also a very energetic and tenacious advocate for gun rights, and some of the invalid arguments he deploys against me might have a worthy place in a brief filed with a court. But they are not analytically effective responses to a scholarly article. For more detail, see my new article Stephen P. Halbrook’s Confused Defense of Bruen’s Novel Interpretive Rule.

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