Following the decision in District of Columbia v. Heller, which was one of the few cases involving the interpretation of the Second Amendment, Professor Lawrence B. Solum published a paper elucidating the reason as why the majority and minority of the court reached the decision they had distinctly supported, and how the two groups differed due to varying beliefs as to how the constitutional text should be interpreted and constructed. Justice Scalia, who wrote the opinion for the majority, instituted the “original public meaning” technique of interpretation, whereas Justice Stevens attempted to employ the “original intentions” technique. Solum goes through a long, drawn out discourse distinguishing these two methodologies of interpretation as
