Like the scholars, the lower federal courts are split on the issue, although their split is the opposite of the scholarly one: most federal courts which have stated a firm position have said that the Second Amendment is not an individual right. [FN13] The federal courts which follow the academic Standard Model *105 are in the minority, although the ranks of the minority have grown in recent years. [FN14] The courts on both sides, like the scholars, insist that they are following the Supreme Court.
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