The inferior courts are trying to write words into the Bruen just like they did Heller and McDonald.
www.law.cornell.edu
Heller's holdings clearly indicate that "The
Second Amendment protects an individual right to possess a firearm unconnected with service in a militia, and to use that arm for traditionally lawful purposes, ..." However, before Bruen, they focus on the clause in that holding ('such as self-defense within the home') much like they do the prefatory clause of the second ("A well regulated Militia, being necessary to the security of a free State, ")
Now, under Bruen, they are again writing in "for self defense" into Heller's syllabus 1(f) holding referencing Miller:
United States v.
Miller,
307 U. S. 174 , does not limit the right to keep and bear arms to militia purposes, but rather limits the type of weapon to which the right applies to those used by the militia,
i.e.,
those in common use for lawful purposes. Pp. 47–54.
By purposely misquoting "lawful purposes" as "self defense", they change the the holding in what a casual observer may see as insignificant. However the change is extreme and should rise to immediate writ of certiorari from the Supreme Court as it has a major effect on a fundamental, enumerate right.
Self defense is a small fraction of "lawful purposes" and the inferior courts are clear that they only mean self defense against individual criminal civilians within their definition.
This is in direct conflict with the Heller decision where the court addresses the "security of a free state" with this statement:
Third, when the able-bodied men of a nation are trained in arms and organized, they are better able to resist tyranny.
A clear definition of tyranny is that of oppression enforced by governments:
Definition of TYRANNY
Therefore the 2nd's protection must encompass those arms and actions that allow a citizenry to dissuade or expel tyrannical actions by government powers, foreign or domestic.
"Lawful Purposes" clearly includes self defense against criminal elements of society but also includes all actions that do not abridge the core rights of other citizens (life, liberty and property) including the right/duty to secure the Constitution from unlawful, tyrannical acts.