Writing for the Court, Justice Henry Billings Brown held that the Second Amendment’s protection of the right to keep and bear arms did not prevent the states from passing laws that restrict the carrying of dangerous weapons. He added, however, that since the Second Amendment is only relevant to the federal government, so “we [the Court] think there is no Federal question properly presented by the record in this case, and that the writ of error must be dismissed upon that ground.” In his brief explanation, he wrote, “We have examined the record in vain, however, to find where the defendant was denied the benefit of any of these provisions, and even if he were, it is well settled that the restrictions of these amendments operate only upon the Federal power, and have no reference whatever to proceedings in state courts.”

He concluded, “[a]s the proceedings were conducted under the ordinary forms of criminal prosecutions there certainly was no denial of due process of law, nor did the law of the State, to which reference was made, abridge the privileges or immunities of citizens of the United States.”