Bellesiles was cited in a state court (appellate) opinion from 2001. That case, Oregon v. Hirsch, 34 P.3d 1209, 1211 (Ct. App. Ore. Oct. 31, 2001) (Landau, P.J.), is apparently the only judicial opinion—state or federal—to cite Bellesiles’ Arming America.
Judge Landau (later Justice Landau) would go on to cite Bellesiles’ Arming America on two further occasions. See Jack L. Landau, The Unfinished Revolution: Interpreting the Oregon Constitution, 62 Oregon St. Bar Bul. 9, 16 & n.42 (Nov. 2001) (“Experts have disagreed—sometimes quite acrimoniously—about what the framers intended that provision of the federal constitution [i.e., the Second Amendment] to mean, while new evidence and explanations emerge almost constantly.” (citing to Arming America)); Jack L. Landau, A Judge’s Perspective on the Use and Misuse of History in State Constitutional Interpretation, 38 Valpo. U. L. Rev. 451, 472 n.92 (2004) (illustrating that Oregon v. Hirsch cites to Arming America); id. at 472 (“Fortunately, I had cited [Bellesiles’] work for a fairly uncontroversial point, but I nevertheless found unsettling the fact that the reliability of an award-winning work of history could be so quickly called into question.” (footnote omitted) (emphasis added)). “Called into question”— how very judicious. A model for us all.
Seth Barrett Tillman, ‘A Model For Us All,’ New Reform Club (Aug. 17, 2026, 6:34 AM), <https://reformclub.blogspot.com/2026/08/a-model-for-us-all.html>;
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