I was not aware of that. Do you have any links or court cases which support that?
152. See Bliss v. Commonwealth, 12 Ky. (2 Litt.) 90 (1822).
If, therefore, the act in question imposes any restraint on the right, immaterial what appellation may be given to the act, whether it be an act regulating the manner of bearing arms or any other, the consequence, in reference to the constitution, is precisely the same, and its collision with that instrument equally obvious.
This is from The Second Amendment in the Nineteenth Century by David Kopel
http://davekopel.org/2a/LawRev/19thcentury.htm#N_153_