The bulletproof case for concealed carry laws?
The word "bear" in the "keep and BEAR arms" part of the 2nd Amendment.
This, from Wikipedia...
In commentary written by Justice Cummings in United States v. Emerson, the United States Court of Appeals for the Fifth Circuit concluded in 2001 that:[48]
"there are numerous instances of the phrase 'bear arms' being used to describe a civilian's carrying of arms. Early constitutional provisions or declarations of rights in at least some ten different states speak of the right of the 'people' [or 'citizen' or 'citizens'] "to bear arms in defense of themselves [or 'himself'] and the state,' or equivalent words, thus indisputably reflecting that under common usage 'bear arms' was in no sense restricted to bearing arms in military service."[49]
Free citizens should not need ANY permission from the government to bear arms for defense.
The way the Heller ruling came out they may be able to get away with saying you can only “bear” arms in your own home!