that its use could contribute to the common defense. In addition, Justice McReynolds wrote: With obvious purpose to assure the continuation and render possible the effectiveness of such forces the declaration and guarantee of the Second Amendment were made. It must be interpreted and applied with that end in view. Interpretations Gun control advocates argue that the United States Circuit Courts, with very few exceptions, have for over six decades cited Miller in rejecting challenges to federal firearms regulations. Gun rights advocates claim the case as a victory because they interpret it as stating that ownership of weapons for efficiency or the preservation of a well-regulated militia unit is specifically protected. Furthermore, they frequently point out that short-barreled shotguns (with 20-inch barrels) have been commonly used in warfare and that the statement made by the judges indicates that they were not made aware of this fact. Because the defense did not appear, there was arguably no way for judges to know otherwise. Two of the justices involved in the decision had prior military experience, Justice Black as a captain in the field artillery during World War I and Justice Frankfurter as a major in the Army legal service; however, there is no way to know if they were personally aware of the use of shotguns by American troops. During World War I, between 30,000 and 40,000 short-barreled pump-action shotguns were purchased by the US Ordnance Department and saw service in the trenches and for guarding German prisoners. Some argue that fundamental issues related to the case were never truly decided because the Supreme Court remanded the case to the federal district court for "further proceedings", which never took place. By the time of the Supreme Court decision, Miller had been killed, and since Layton made a plea bargain after the decision was handed down, there were no claimants left to continue legal proceedings. The US Supreme Court has mentioned Miller in only seven subsequent cases: Konigsberg (1961); Atlanta Motel (1964); Adams (1972); Lewis (1980); Printz (1997); Heller (2008) and McDonald v. City of Chicago (2010); Justice James Clark McReynolds authored the decision in United States v. Miller, the only Supreme Court case that directly involved the Second Amendment until District of Columbia v. Heller in 2008. Here are the Supreme Court's interpretations of the 1939 Miller opinion: Konigsberg v. State Bar (1961); Footnote 10 That view, which of course cannot