It is similar in basic subject matter to several other cases, such as " Woollard v . Sheridan " and " Moore v . Madigan ", filed in the wake of the landmark Supreme Court decision in " McDonald v . Chicago " which applied the Second Amendment as a check on State power as well as Federal, under the selective incorporation doctrine.
12.
The Court does go on to find, through its selective incorporation doctrine, that the Fourth Amendment's proscription of unreasonable searches and seizures is " implicit in the concept of ordered liberty, and as such enforceable against the States through the Due Process Clause . " However, enforcement of this basic right raises further questions, e . g ., how to check such police conduct, what remedies are appropriate against it, and so forth.
13.
Although significant portions of " Cruikshank " have been overturned ( either explicitly or by implication ) by later decisions, most notably the 5 4 " District of Columbia v . Heller " ruling in 2008, it is still relied upon with some authority in other portions . " Cruikshank " and " Presser v . Illinois ", which reaffirmed it in 1886, are the only significant Supreme Court interpretations of the Second Amendment until the murky " United States v . Miller " in 1939, but both preceded the court's general acceptance of the incorporation doctrine and have been questioned for that reason.
