Oxford University has an article about the Second Amendment and how it raised issues on gun control. Oxford University stated that “In Presser v. Illinois (1886) the Court held that the 2nd Amendment applied only to the federal government and did not prohibit state governments from regulating an individual's ownership or use of guns”. After the Court let a stand by the Seventh Circuit Court of Appeals, it was concluded that the 2nd Amendment remains one of the few provisions of the Bill of Rights that is not “incorporated” under the due process clause of the 14th Amendment and thereby applied to state governments. Near the end of Oxford University’s article, they stated that “at present, state governments are not prohibited by the 2nd Amendment from enacting gun control laws”. State courts have tended to uphold local ordinances and state laws to regulate or control ownership of guns. The Second Amendment “had no other effect than to restrict the power of the National Government” in matter pertaining to “those arms which are necessary to maintain well-regulated militia.” The evidence in Oxford University’s article is important because it explains the restrictions in the Second Amendment and how it is affected with gun control laws. The article is also important because it explains how some states have taken action to gun possession and how the Court has taken many different approaches to gun control.