I agree with Gaijin42 Just give the facts Describing the era between Miller and Heller as favoring the collective right viewpoint would run into the ban on synthesis It s better to simply refer to the disagreement in the legal academic and political communities during that period Also McDonald did not overrule any Supreme Court decisions Only Justice Thomas would have done so The plurality opinion distinguished those earlier decisions e g Cruikshank on the ground that those decisions ruled that the Second Amendment was not incorporated via the Privileges or Immunities Clause of the Fourteenth Amendment but did not discuss the Due Process Clause The plurality ruled that those decisions were not precedent for whether the Second Amendment could be incorporated via the Due Process Clause The plurality opinion is the de facto Opinion of the Court because it is the opinion that supports the holding and is based on the narrowest grounds see Marks v United States