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The main problem, as I see it, is that the members of the U.S. Supreme Court are illiterate or at least poorly educated when it comes to our English language. Madison, Jefferson, et al. were schooled in both Latin (that always helps) and proper grammar and so knew exactly what they intended in writing the Second Amendment.
Henceforth, let all hearings on a nomination to the Supreme Court begin with a test of the candidate's knowledge of English grammar.
"A notable example of an absolute construction in English is the sentence composing the Second Amendment to the United States Constitution: 'A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed.'
"In this example, 'A well regulated Militia, being necessary to the security of a free State' serves as the absolute clause. Use of this construction to introduce a justification clause was not unusual during the time the amendment was written, but because of its unfamiliarity to present-day English speakers, this interpretation is somewhat contentious."