—holding that the right to bear arms refers to arms used for purposes of war, and that the legislature may prohibit wearing of such weapons as are not used in civilized warfare and would not contribute to the common defense

It is manifest from the language of the [Second Amendment]... that the arms which it guarantees American citizens the right to keep and to bear, are such as are needful to, and ordinarily used by a well regulated militia

When States generally prohibited both open and concealed carry of handguns in the late-19th century, state courts usually upheld the restrictions when they exempted army revolvers, or read the laws to exempt at least that category of weapons.

"Under this head, with a knowledge of the habits of our people, and of the arms in the use of which a soldier should be trained, we would hold that the rifle of all descriptions, the shot-gun, the musket and repeater are such arms; and that under the constitution the right to keep such arms cannot be infringed or forbidden by the legislature."

—upholding statute prohibiting "the carrying, as a weapon,[of] `any pistol of any kind whatever,'"as a lawful" exercise of the police power of the State without any infringement of the constitutional right "to bear arms

—upholding a prohibition against carrying pistols in public because such weapons are "used in private quarrels and brawls" and are not "effective as a weapon of war, and useful and necessary for `the common defense

—staked its position on two interpretations of the Second Amendment right that the Heller Court repudiated—and from which the Arkansas court itself later retreated.

—"passed to subserve the general good, so as not to infringe the right secured, and the necessary incidents to the exercise of such rights,"

Moreover, other state court cases decided around that same time suggest that bans on carrying guns in both a concealed and open manner are constitutional.

Miln, 11 Pet.[102] 139, the'powers which relate to merely municipal legislation, or what was perhaps more properly called internal police,''not surrendered or restrained'by the constitution of the United States.'