A Los Angeles Times account of Malcolm Gladwell's book The American Way of Killing presents him as tracing the Court's Second Amendment stance to Sir John Knight's 1686 armed church incident and acquittal in Bristol. Bruen in 2022 discussed that matter on one page after both sides raised it, while Heller omitted it entirely, and the majority surveyed medieval through Reconstruction laws finding no continuous ban on peaceful public carry. Gladwell as portrayed prefers common sense to history when assessing special-need requirements.