would lead down the path to a complete ban on gun ownership", "is now gone." Helmke added that, "The Court also rejected the absolutist misreading of the Second Amendment that some use to argue 'any gun, any time for anyone,' which many politicians have used as an excuse to do nothing about the scourge of gun violence in our country and to block passage of common sense gun laws." Reactions To the lower court rulings Various experts expressed opinions on the D.C. Circuit's decision. Harvard Law School professor Laurence Tribe contended that the Second Amendment protects an individual right, and predicted that if Parker is reviewed by the Supreme Court "there's a really quite decent chance that it will be affirmed." However, Professor Tribe has also argued that the District's ban on one class of weapons does not violate the Second Amendment even under an individual rights view. Erwin Chemerinsky, then of Duke Law School and now dean of the University of California, Berkeley School of Law, argued that the District of Columbia's handgun laws, even assuming an "individual rights" interpretation of the Second Amendment, could be justified as reasonable regulations and thus upheld as constitutional. Professor Chemerinsky believes that the regulation of guns should be analyzed in the same way "as other regulation of property under modern constitutional law" and "be allowed so long as it is rationally related to achieving a legitimate government purpose." However, the dicta in Heller suggests that applying a mere rational basis analysis is an incorrect reading of the Constitution and would, in fact, defeat the entire purpose of the Second Amendment. To the Supreme Court rulings Cato Institute senior fellow Robert Levy, co-counsel to the Parker plaintiffs, agreed with the court's ruling but describes that his interpretation of the Second Amendment would not preclude all governmental regulation of private ownership of weapons: Clark Neily, an attorney for Dick Heller in this case, has said regarding Heller: Richard Posner, judge for the United States Court of Appeals for the Seventh Circuit, compares Heller to Roe v. Wade, stating that it created a federal constitutional right that did not previously exist, and he asserts that the originalist method – to which Justice Antonin Scalia claimed to adhere – would have yielded the opposite result of the majority opinion. J. Harvie Wilkinson III, chief judge of United States Court of Appeals for the Fourth Circuit, consents