the Supreme Court's rulings in District of Columbia v. Heller (2008), and McDonald v. Chicago (2010). In Heller, the Supreme Court resolved any remaining circuit splits by ruling that the Second Amendment protects an individual right. Although the Second Amendment is the only Constitutional amendment with a prefatory clause, such linguistic constructions were widely used elsewhere in the late eighteenth century. Warren E. Burger, a conservative Republican appointed chief justice of the United States by President Richard Nixon, wrote in 1990 following his retirement: The Constitution of the United States, in its Second Amendment, guarantees a "right of the people to keep and bear arms". However, the meaning of this clause cannot be understood except by looking to the purpose, the setting and the objectives of the draftsmen... People of that day were apprehensive about the new "monster" national government presented to them, and this helps explain the language and purpose of the Second Amendment... We see that the need for a state militia was the predicate of the "right" guaranteed; in short, it was declared "necessary" in order to have a state military force to protect the security of the state. And in 1991 Burger stated: If I were writing the Bill of Rights now, there wouldn't be any such thing as the Second Amendment... that a well regulated militia being necessary for the defense of the state, the peoples' rights to bear arms. This has been the subject of one of the greatest pieces of fraudI repeat the word 'fraud'on the American public by special interest groups that I have ever seen in my lifetime. In a 1992 opinion piece, six former American attorneys general wrote: For more than 200 years, the federal courts have unanimously determined that the Second Amendment concerns only the arming of the people in service to an organized state militia; it does not guarantee immediate access to guns for private purposes. The nation can no longer afford to let the gun lobby's distortion of the Constitution cripple every reasonable attempt to implement an effective national policy toward guns and crime. Research by Robert Spitzer found that every law journal article discussing the Second Amendment through 1959 "reflected the Second Amendment affects citizens only in connection with citizen service in a government organized and regulated militia." Only beginning in 1960 did law journal articles begin to advocate an "individualist" view of gun ownership rights.