Too many courts are trying to claim that Heller only addressed possession in the home. In fact, the SCOTUS spoke primarily to "in the home" in Heller for the simple reason that the lawsuit was about possession in the home.
Once you get beyond that, any high school English teacher can tell you that a sentence reading "The right to keep and bear arms shall not be infringed" is talking about ONE right, not two. The gun grabbers love to paint the SCOTUS as "activist" when they support the RKBA, but they are silent when a truly activist lower court tries to divide what is clearly ONE right into two rights: (1) a right to "keep" arms (only in the home -- a word and concept not appearing in the 2nd Amendment at all); and (2) a separate right to "bear" arms.
That said, even if it were construed as two separate and independent rights, the 2nd Amendment still says they "shall not be infringed."
This attempt to split what is clearly and grammatically one right into two separate and apparently unrelated rights is nothing more nor less than lower courts thumbing their noses at the SCOTUS. And I am under the impression that more than a few of the nine justices of the SCOTUS become rather testy when they perceive that lower courts are thumbing their noses at them.