In District of Columbia v. Heller (2008), Justice Antonin Scalia, employing originalism, attempts to interpret the rights enshrined in the Constitution according to how the Founders would have understood them. Scalia uses the history of the Second Amendment to prove that the right to bear arms protected an individual’s right to bear arms, unconnected with service in a militia. However, the sources Scalia cites often do not neatly align with, or contradict his conclusions.