Consider what the Heller Court actually said. True, the Court spent many pages in Heller discussing the text and historical context of the Second Amendment. 554 U. S., at 579–619. But that is not surprising because the Heller Court was asked to answer the preliminary question whether the Second Amendment right to “bear Arms” encompasses an individual right to possess a firearm in the home for self-defense. Id., at 577. The Heller Court concluded that the Second Amendment’s text and history were sufficiently clear to resolve that question: The Second Amendment, it said, does include such an individual right. Id., at 579–619. There was thus no need for the Court to go further—to look beyond text and history, or to suggest what analysis would be appropriate in other cases where the text and history are not clear.
The dissent gives the false impression that every American who has qualified to purchase a firearm will now qualify to carry a concealed handgun. As a practical matter, the Government always has procedure as a weapon to combat a substantive law that it does not agree with. That is to say, there will still be many bases to deny permits to carry and most of the aggrieved applicants will not have the means to pursue costly appeals.