U.S. v. Kraase, 340 F.Supp. 147 (E.D. Wis. 1972).
In ruling on a motion to dismiss an indictment, the court rejected a facial constitutional challenge to 18 U.S.C. 922(a)(5)-which prohibited sales of firearms to residents of other states. Recognizing that an individual right was protected, it held that "second amendment protection might arise if proof were offered at the trial demonstrating that his possession of the weapon in question had a reasonable relationship to the maintenance of a ‘well-regulated Militia.`"

Thompson v. Dereta, 549 F. Supp. 297 (D. Utah 1982).
An applicant for relief from disabilities (a prohibited person) brought an action against the federal agents involved in denying his application. The court dismissed the case, holding that, because there was no "absolute constitutional right of an individual to possess a firearm," there was "no liberty or property interest sufficient to give rise to a procedural due process claim."

Vietnamese Fishermen`s Assoc. v. KKK, 543 F.Supp. 198 (S.D.Tex. 1982). Like the statute faced by the Supreme Court in Presser v. Illinois, 116 U.S. 252 (1876), the Texas statute and the injunction at issue here prohibited private military activity. Mis-characterizing Miller, the court held that the Second Amendment "prohibits only such infringement on the bearing of weapons as would interfere with ‘the preservation or efficiency of a well-regulated militia,` organized by the State." Later, however, the court, following Miller, explained that the "Second Amendment`s guarantee is limited to the right to keep and bear such arms as have ‘a reasonable relationship to the preservation or efficiency of a well regulated militia.`" The courts`s understanding of the Second Amendment is thus inconsistent.

U.S. v. Kozerski, 518 F.Supp. 1082 (D.N.H. 1981), cert. denied, 469 U.S. 842 (1984).
In the context of a challenge to the law prohibiting the possession of firearms by convicted felons; the court, while holding correctly (see discussion of Nelson, supra) that the Second Amendment "is not a grant of a right but a limitation upon the power of Congress and the national government," concluded that the right "is a collective right . . . rather that an individual right," citing only Warin. As a district court in the First Circuit, however, the court was bound by Cases, which expressly recognized that the right belonged to individuals.