Last month Rory Little of University of California Law San Francisco argued on SCOTUSblog that Viramontes v. Cook County concerns Cook County Illinois and Connecticut bans on commonly owned semi-automatic rifles including the AR-15 and that Heller protects only founding-era arms. Jonathan Turley of George Washington University Law on September 23 cited Heller and Caetano v. Massachusetts protecting stun guns unknown in 1791. Scalia joined Thomas in a 2015 Friedman v. Highland Park dissent that millions of lawful AR-style owners meet common use and the 2026 National Firearms Survey estimated 60 million rifles owned by one in ten U.S. adults.