Buried in the fine print of the Supreme Court’s 2022 New York State Rifle & Pistol Association v. Bruen ruling sits a single footnote, and lower courts have fallen in love with it. Why? Because it hands them a convenient way to bless gun laws that would otherwise flunk the Second Amendment outright. That footnote, number nine, has now drawn a sharp warning from a federal appeals judge who says it has been twisted beyond recognition.