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United States v. Miller, 307 U.S. 174 (1939) involved the indictment of Jack Miller and a cohort for unlawfully transporting a short-barrelled shotgun in violation of the National Firearms Act of 1934. The trial court granted Miller's motion to dismiss the charges, holding that the section of the act under which he had been indicted violated the Second Amendment. The United States appealed. Jack Miller fled to parts unknown. Only the Solicitor General for the United States filed a brief or appeared to argue the case before the Supreme Court. The Court was not at all concerned that Jack Miller, an individual, was asserting a Second Amendment claim. What the Supreme Court cared about was whether the shotgun possessed by Miller had "some reasonable relationship to the preservation or efficiency of a well-regulated militia, . . ." 307 U.S. at 178. The Court refused to take for granted that a short-barrelled shotgun "is any part of ordinary military equipment or that its use could......

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