The 4th Circuit's decision in Kolbe et al v. Maryland was a direct, if often legally incomprehensible attempt to greatly limit the Supreme Court's seminal decision in Heller and set the stage for a new national ban on semi-automatic rifles. Heller held that the 2nd Amendment confers an individual not a collective right to keep and bear arms. Kolbe, so long as it stands, says this individual right does not extend to any firearm with military utility, which is arguably pretty much every gun ever made.