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Miller, which was a poorly written decision IMHO and Justice Kennedy's too, upheld the 1934 NFA that required sawed-off shotguns to be registered and taxed. The court IIRC said that the 2A did not protect Miller from the restrictions of the NFA unless he could show that the weapon had a militia relationship.
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IANAL but would appreciate input from any lawyers on this topic. I do not read
Miller as reaching the above conclusions.
Miller came to the Supreme Court as a government appeal of the dismissal of NFA charges against Miller. In that
dismissal, the District Court had declared the NFA unconstitional without any discussion or statement of rationale - just a conclusion. The Supreme Court decision in
Miller was to reverse and remand. In essence the Supreme Court said no evidence was presented (since there was no District Court trial and no defense brief before the Supreme Court) to support the District Court's conclusion, so reinstate the charges against Miller and have a trial.
Did the Supreme Court uphold the NFA? I think the Supreme Court reversed an unsupported conclusion that the NFA was unconstitutional and sent the case back to the District Court "for further proceedings."
Did the Supreme Court say that the 2A did not protect Miller? I think that the Supreme Court said that such an argument had not been made ("In the absence of any evidence tending to show that possession or use of a 'shotgun having a barrel of less than eighteen inches in length' at this time has some reasonable relationship to the preservation or efficiency of a well regulated militia, we cannot say that the Second Amendment guarantees the right to keep and bear such an instrument.").
In my opinion, there was not much to
Miller, but much was made out of it over the years because it was the only 2A case before the Supreme Court for the better part of a century