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This is a case of first impression and Judge Cummings has just signaled that he is too afraid to touch it.
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I don't think that is the case as Judge Cummings was also the district judge in
Emerson and was basically the first judge in the last two decades to find an individual right in the Second Amendment. I'd guess his finding has less to do with fear of rocking the boat and more to do with a genuine belief.