The History of Repeating Arms Gun-Control Groups Don’t Want the Courts to Know

by
posted on September 16, 2026
** When you buy products through the links on our site, we may earn a commission that supports NRA's mission to protect, preserve and defend the Second Amendment. **

This episode of NRA’s The Armed Citizen Podcast refutes one of the biggest false claims gun-control groups and the politicians they support repeat ad nauseam by asserting that the Founding Fathers could not have imagined the AR-15.

The historical truth is, as Joe Greenlee, director of the Office of Litigation Counsel at the NRA Institute for Legislative Action, explains, repeating arms were definitely known to the Founding generation—and to generations before.

To make sure the U.S. Supreme Court is aware of this history before the court hears the consolidated cases Viramontes v. Cook County and Grant v. Higgins, which challenge the “assault-weapons” bans of Cook County, Illinois and Connecticut, Greenlee helped to write an amicus brief to advise the justices.

This brief to the high court is a must-read for anyone who wants to understand this issue; in fact, it should be mandatory reading for every journalist in America.

The U.S. Supreme Court has repeatedly ruled—in Heller (2008) and Bruen (2022), for example—that the Second Amendment protects arms that are in common use. This includes semi-automatics. Heller, in fact, specifically ruled that semi-automatic pistols have common-use protections.

“The Court has said the Second Amendment extends to modern arms,” says Greenlee in this podcast interview. “But nevertheless, lower courts have said, well, these semi-automatic firearms, the assault weapons at issue in the Viramontes case, represent a dramatic technological change, and so, therefore, we don’t have to follow what the Supreme Court has said in their opinions.”

To show the actual history of firearms advances, NRA-ILA helped to research and write a brief to “demonstrate that semi-automatic firearms are not some dramatic technological change and instead, they are the latest step in just a very long—I mean 500 year long—continuous process in which people have made incremental improvements to repeating arm technology,” said Greenlee.

To make this clear, the NRA’s brief traces the history of repeating arms from their first appearance around 1490 to show that modern semi-automatic rifles are not a “dramatic technological change,” but instead are the product of five centuries of incremental advances in repeating-arm technology.

“To be clear, if restrictions on semi-automatic handguns do not warrant a ‘more nuanced’ historical analysis, restrictions on semiautomatic rifles do not either,” said Greenlee.

The Founders had a lot of exposure to repeating arms. Successful repeaters emerged in 17th century Europe with the Kalthoff and Lorenzoni designs. In 1777, the Continental Congress actually ordered 100 of Joseph Belton’s repeaters after he successfully demonstrated a 16-shot musket—this order was later rescinded when Belton outlined the costs for making 100 of his repeaters.

Still, within two years of the Second Amendment’s ratification, Joseph Chambers—who would later sell numerous types of repeating arms to the U.S. Navy and Pennsylvania militia— demonstrated his repeater for Secretary of State Thomas Jefferson and even corresponded with President George Washington about it.

A few years later, the 22-shot Girardoni air rifle was famously carried on the Lewis and Clark Expedition to help Meriwether Lewis and William Clark protect themselves and their men on the 1804-06 expedition to the Pacific Ocean.

In this episode, Greenlee explains the storied history of the development of repeating rifles. It is a history full of interesting characters, fantastical designs, and huge advances in firearms made to win wars as well as to protect citizens at home and as they traveled.

Latest

Eaa Girsan Witness2311 Matchx Rifleman Review 1
Eaa Girsan Witness2311 Matchx Rifleman Review 1

Rifleman Review: EAA Corp. Girsan Witness2311 Match X

One of the latest 2011-style handguns out from European American Armory Corp. is its Girsan Witness2311 MatchX platform, which includes a built-in, single-port compensator and is designed for competition use.

Shell Shock & CBC Global Ammunition Sign Manufacturing Agreement

Shell Shock Technologies (SST) and CBC Global Ammunition have signed an agreement that adds manufacturing capacity, advanced tooling and new SST operations in Oklahoma and Michigan.

Short & Sweet: Springfield Armory's SA-35 4" Polished Blued

Springfield Armory continues to expand its SA-35 High Power handgun line, and one of the latest versions is this new SA-35 4" Polished Blued model that provides some added luster while remaining compact.

75 Years of CCI

What better time to look at what’s new at CCI than when the company's celebrating 75 years in business?

The Galactic Pistol Alliance: An Entry Point For New Competition Shooters

Galactic Pistol Alliance jettisons rule confusion and offers a much more relaxed model for newcomers to competition shooting, all while keeping cool shooting stages and an emphasis on safety.

NRA Supporter & Gold Expert Mike Fuljenz Wins Newsletter Award

Longtime NRA Supporter Mike Fuljenz, founder of Universal Coin & Bullion, was awarded the 2026 Best Investment Newsletter award by the Numismatic Literary Guild. 

Interests



Get the best of American Rifleman delivered to your inbox.