For nearly seven decades before Heller, Miller was the Supreme Court decision most frequently cited in debates about the scope of the Second Amendment.
The case arose under the NFA
The defendants were charged with transporting an unregistered short-barreled shotgun in interstate commerce in violation of the National Firearms Act.
The Court focused on militia relationship
The Court said the record did not show that a short-barreled shotgun had a reasonable relationship to preservation or efficiency of a well regulated militia.
Miller generated competing readings
Later courts and scholars disagreed over whether Miller supported a collective-right view, a weapon-type test, or a narrower ruling driven by the undeveloped record.
Heller reinterpreted Miller’s place in doctrine
Heller held the Second Amendment protects an individual right while reading Miller as consistent with limits on the types of weapons protected.
Where this fits in the larger timeline
This event is part of the History of Gun Laws in America series. Federal firearm law developed incrementally through constitutional amendments, taxation and commerce statutes, criminal prohibitions, background-check legislation and modern Second Amendment decisions.