United States v. Miller, 307 U.S. 174 (1939). In perhaps the most cited Supreme Court case on the Second Amendment, the Court held that the “obvious purpose” of the Second Amendment was to “assure the continuation and render possible the effectiveness of” the state militia, and the Amendment “must be interpreted and applied with the end in view.” Essentially, the focus of the Second Amendment was to protect the rights of states to form militias, not the rights of individuals to own guns, and that the protections of the Second Amendment must be understood within the context of militia service. However, the Supreme Court hinted that an individual right may exist in the context of a “common obligation … to possess arm … and to cooperate in the work of defense” and that a sawed-off shotgun, the firearm at issue in the case, was unprotected because it had no “reasonable relationship to the preservation or efficiency of a well-regulated militia.” This implied that all “free men” could possess weapons of the type used for militia service, but the Court halted this argument by insisting that only those guns usable in militia service and held for the purpose of militia service were protected by the Second Amendment