What is the test for establishing that a right to keep and bear arms is a fundamental, individual right?

MultiRegion, United States of America

The following excerpt is from Peterson v. Farrow, No. 2:15-cv-00801-JAM-EFB (E.D. Cal. 2016):

Temple contends that "[t]he right to keep and bear arms is a fundamental, individual right, requiring the application of strict scrutiny to the challenged statutes." Opp'n 4:18-21 (citing District of Columbia v. Heller, 554 U.S. 570 (2008)).

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