In Wolford v. Lopez (No. 241046), the U.S. Supreme Court granted review of whether Hawaii may presumptively prohibit licensed concealed carry holders from carrying firearms on private property that is open to the public absent express permission from the owner — a rule critics call the “vampire rule.”
As Americans await the Court’s decision, one fact is undeniable: the modern American militia is not theoretical—it is vast, practical, and alive.
The Numbers Are Unmistakable
Conservative estimates place civilian-owned firearms in the United States at roughly 500 million — more guns than people — based on manufacturing and import data compiled by industry and federal reporting agencies. Industry analysis from the National Shooting Sports Foundation (NSSF) shows that 491 million firearms were in civilian hands from 1990–2022, and this number has almost certainly grown to well over 500 million today, consistent with the estimates cited earlier in this article.
While comprehensive annual ammunition figures aren’t consolidated in a single federal database, reporting from the firearms industry indicates that U.S. ammunition production is measured in the billions of rounds each year — with past estimates showing as many as 8.1 billion rounds produced for the U.S. market in a single year. When accumulated over decades of lawful purchase and storage, civilian stockpiles of ammunition likely exceed one trillion rounds, reflecting the scale and preparedness of America’s private, law-abiding gun owners.
These are not numbers of idle hobbyists. Many Americans do not hunt, nor participate in organized shooting sports, yet continue to purchase and store firearms and ammunition. They do so because it is the fabric of who we are as a free nation. History has taught us from our earliest education that Americans have repeatedly had to fight—for independence from a tyrant king, for freedom across the world during WWII, and for the ability to pass liberty to future generations. We prepare and maintain our arms not out of fear, but because it is our responsibility as Americans, reflecting a citizen militia that is ever ready to defend the freedoms enshrined in our Constitution.
The Citizen Militia Is Not a Concept—It Is a Responsibility
Wolford v. Lopez raises a critical question under the Second Amendment and the Court’s Bruen decision framework: can a state effectively nullify the right to public carry by making “no guns” the default on private property open to the public unless invited?
The Court heard oral arguments on January 20, 2026, and the transcript is publicly available from the U.S. Supreme Court.
Founders’ Vision of an Armed Citizenry
The framers spoke repeatedly about an armed citizenry as essential to liberty:
George Mason: “To disarm the people… [is] the best and most effectual way to enslave them.”
James Madison: “The advantage of being armed… forms a barrier against the enterprises of ambition.”
Thomas Jefferson: “No free man shall ever be debarred the use of arms.”
George Washington: “A free people ought not only to be armed, but disciplined…”
Richard Henry Lee: “To preserve liberty it is essential that the whole body of the people always possess arms…”
Samuel Adams: “Peaceable citizens [must not] be prevented from keeping their own arms.”
These historical voices remind us that an armed citizenry was essential to liberty, not optional.
Why This Matters Today
In an era of terrorism, violent crime, and emergencies, law enforcement cannot be everywhere. Seconds matter. A prepared citizen can protect families and communities when official responders are not immediately available.
“Freedom survives only in the hands of the prepared. The citizen militia envisioned by our Founders still lives.”
America’s 250th Anniversary: A Time to Reflect and Defend
As we approach the 250th anniversary of the United States, the Founders’ vision—an armed, responsible, and capable citizenry—still exists. But freedom is never self-executing; it must be defended in the courts, the culture, and in the public square.
The citizen militia lives. The Republic endures. The responsibility to protect both remains with us.
A Call to Duty for Future Generations
We are the inheritors of sacred trust. The Founders forged a nation on the principles of liberty and self-governance, and every generation since has carried that torch forward through courage, sacrifice, and, when necessary, with their lives. It is our duty to ensure that freedom does not erode, that the Constitution’s God-given rights are defended, and that the flame of liberty burns brighter in the hands of those who come after us.
We must equip future generations with knowledge, instill in them the discipline to act, and awaken in them the desire to protect what was so dearly fought for and won. The fight for liberty never finishes; it continues as long as we are willing to stand as the bedrock of freedom, safeguarding the inheritance of our children, grandchildren, and all who will call America home.
Above all, we must ensure that this great experiment in self-government endures and that the freedom we enjoy as Americans remains constant for generations to come.
Why the Ninth Circuit Keeps Losing—and Why Wolford v. Must End Judicial Defiance
About Sean Maloney.
Sean Maloney is a criminal defense attorney, co-founder of Second Call Defense, and an NRA-certified firearms instructor. He is a nationally recognized speaker on critical topics including the Second Amendment, self-defense, the use of lethal force, and concealed carry. Sean has worked on numerous use-of-force and self-defense cases and has personally trained hundreds of civilians to respond safely and legally to life-threatening situations. He is a passionate advocate for restoring the cultural legitimacy of the Second Amendment and promoting personal responsibility in self-defense.
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