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The Second Amendment secures the right not only to “keep” arms but also to “bear” them—the verb whose original meaning is key in this case. Saving us the trouble of pulling the eighteenth-century dictionaries ourselves, the Court already has supplied the word’s plain meaning: “At the time of the founding, as now, to ‘bear’ meant to ‘carry.’” Heller, 554 U.S. at 584.3 Yet, not “carry” in the ordinary sense of “convey[ing] or transport[ing]” an object, as one might carry groceries to the check-out counter or garments to the laundromat, but “carry for a particular purpose—confrontation.” Id. The “natural meaning of ‘bear arms,’” according to the Heller majority, was best articulated by Justice Ginsburg in her dissenting opinion in Muscarello v. United States, 524 U.S. 125 (1998): to “‘wear, bear, or carry . . . upon the person or in the clothing or in a pocket, for the purpose . . . of being armed and ready for offensive or defensive action in a case of conflict with another person.’”
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Speakers of the English language will all agree: “bearing a weapon inside the home” does not exhaust this definition of “carry.” For one thing, the very risk occasioning such carriage, “confrontation,” is “not limited to the home.” Moore v. Madigan, 702 F.3d 933, 936 (7th Cir. 2012). One needn’t point to statistics to recognize that the prospect of conflict—at least, the sort of conflict for which one would wish to be “armed and ready”—is just as menacing (and likely more so) beyond the front porch as it is in the living room. For that reason, “[t]o speak of ‘bearing’ arms within one’s home would at all times have been an awkward usage.”
