<P> In the latter half of the 20th century, there was considerable debate over whether the Second Amendment protected an individual right or a collective right . The debate centered on whether the prefatory clause ("A well regulated militia being necessary to the security of a free State") declared the amendment's only purpose or merely announced a purpose to introduce the operative clause ("the right of the People to keep and bear arms shall not be infringed"). Scholars advanced three competing theoretical models for how the prefatory clause should be interpreted . </P> <P> The first, known as the "states' rights" or "collective right" model, held that the Second Amendment does not apply to individuals; rather, it recognizes the right of each state to arm its militia . Under this approach, citizens "have no right to keep or bear arms, but the states have a collective right to have the National Guard". Advocates of collective rights models argued that the Second Amendment was written to prevent the federal government from disarming state militias, rather than to secure an individual right to possess firearms . Prior to 2001, every circuit court decision that interpreted the Second Amendment endorsed the "collective right" model . However, beginning with the Fifth Circuit's opinion United States v. Emerson in 2001, some circuit courts recognized that the Second Amendment protects an individual right to bear arms . </P> <P> The second, known as the "sophisticated collective right model", held that the Second Amendment recognizes some limited individual right . However, this individual right could only be exercised by actively participating members of a functioning, organized state militia . Some scholars have argued that the "sophisticated collective rights model" is, in fact, the functional equivalent of the "collective rights model ." Other commentators have observed that prior to Emerson, five circuit courts specifically endorsed the "sophisticated collective right model". </P> <P> The third, known as the "standard model", held that the Second Amendment recognized the personal right of individuals to keep and bear arms . Supporters of this model argued that "although the first clause may describe a general purpose for the amendment, the second clause is controlling and therefore the amendment confers an individual right' of the people' to keep and bear arms". Additionally, scholars who favored this model argued the "absence of founding - era militias mentioned in the Amendment's preamble does not render it a' dead letter' because the preamble is a' philosophical declaration' safeguarding militias and is but one of multiple' civic purposes' for which the Amendment was enacted". </P>

Which of the following adopted the individual right to the second amendment