Second Amendment legal scholar Stephen Halbrook, who has won three firearms cases before the U.S. Supreme Court, has argued in several Independent Institute books and articles that civil liberties are more secure when individuals have legal access to firearms. His 2003 book, "The Founders’ Second Amendment", traced the U.S. Constitution's guarantees of “the right of the people to keep and bear Arms” back to the American colonists’ fears of British oppression. His 2013 book, "Gun Control in the Third Reich", examined firearm registration and restrictions in pre-World War II Germany.