[Texas Federalist]

Of course Miller didn't appear, and the Court could not just presume facts not in evidence.

Exactly. The actual holding of the decision was that the Court was not able to take judicial notice of the fact that a sawed off shotgun could be used by a militia. Presumably, if some evidence were presented, ANY weapon could fit in this category.

[robertpaulsen]

And what if they couldn't present evidence that the weapon bore some relationship to a well regulated militia?

"ANY weapon could fit in this category."

Doubtful. If that was the case, the U.S. Supreme Court never would have remanded the case.