Heller did no such thing. All supreme court's have referenced Miller vs US as the standard. And FYI supreme court's rulings when it comes to constitutionally protected rights are never over turned. Miller you dumb son of a bitch started the in common use defense of the second amendment which all supreme court's have used. Simp you need to take a few classes.God what a flippin dumbass. Heller overturned the precedent that was Miller you stupid shit. And he never even mentions Miller in his opinion.