Virginia ratifies the Bill of Rights, enshrining the right to bear arms in the Second Amendment

James Madison drafted the Second Amendment and Congress sent it to the states for ratification alongside nine other amendments on September 25, 1789. Virginia became the decisive state ratifying the Bill of Rights on December 15, 1791, enshrining the text: "A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed." Anti-Federalists had insisted on the amendment to guard against federal disarmament of state militias after memories of British confiscation attempts during the Revolutionary War. For nearly two centuries, federal courts interpreted the amendment primarily as protecting militia-related arms bearing rather than an individual right.