A year ago, when the Supreme Court finally ruled “that the Second Amendment confer[s] an individual” -- rather than a collective state-held -- “right to keep and bear arms,” we noted that the decision was just the start of constitutional litigation concerning the Second Amendment. “The supreme ricochet has begun,” we observed. (Read: The Supreme Ricochet Has Begun)

We said that because, despite the unquestionable importance of and long-fought battle for the Supreme Court’s landmark ruling in District of Columbia v. Heller, No. 07-290, the decision raised more questions than it answered. As we explained, “[t]he numerous questions left open by the Heller decision will be ricocheting for years through not only the courts, but also the White House, the Congress, governor’s mansions, state legislatures, mayor’s offices and city councils nationwide.”

Indeed, though Americans may have believed that Heller granted everyone across our country a constitutionally protected “right of the people to keep and bear Arms,” that actually was not technically true at all. This was why, within day of the Heller ruling, the National Rifle Association, the Second Amendment Foundation and others filed new challenges to the restrictive gun laws that continued not only to be on the books but also enforced in the metropolitan Chicago area. As weeks and months passed, other cases followed.

The Heller case was brought as a Second Amendment challenge to what were then the most restrictive gun laws in the United States, which happened to be those in the District of Columbia. But the location in our nation’s capital was more important than mere coincidence because, under longstanding precedent, the Bill of Rights applies directly to the federal government, including the territory it controls as “the Seat of the Government of the United States” (i.e., D.C.).

In other words, constitutionally speaking, just because citizens enjoy “an individual right to keep and bear arms” in D.C. because of the Heller ruling on the Second Amendment, that doesn’t necessarily mean citizens in the rest of the country enjoy the same constitutional right. We know that sounds crazy but, under our federal-state system, the Supreme Court has “selectively incorporated” (or applied) the various protections found in the Bill of Rights against the states through the Fourteenth Amendment on a case-by-case basis.

Thus, the justices made it clear in Heller that, at least then, they were only deciding the D.C. case in front of them, leaving open the question of whether the Second Amendment’s protection of “an individual right to keep and bear arms” would apply just the same to all 50 states.

This is why the Court noted in Footnote 23 that the application of the Second Amendment to the states through “incorporation [was] a question not presented by [the Heller] case,” and further that earlier decisions had “reaffirmed that the Second Amendment applies only to the Federal Government.”

But in that very same footnote, the Supreme Court suggested that, if the right case was brought, the Second Amendment would be applied to the rest of the country through the constitutional doctrine of selective incorporation. In fact, the very first sentence of Footnote 23 specifically pointed out that the leading case discounting application of the Second Amendment to the states “also said that the First Amendment did not apply against the States and did not engage in the sort of Fourteenth Amendment inquiry required by our later cases.” That case was more than 125 years old.

Fast forward a year and the day that the Second Amendment will be applied to the states by the Supreme Court may be coming very soon.

Since January, three federal appellate courts have decided cases requiring them to provide their opinion as to whether the Second Amendment protects “an individual right to keep and bear arms” in the states.

In California, the U.S. Court of Appeals for the Ninth Circuit ruled that the Second Amendment did apply to the states. But in both New York and Illinois, the U.S. Courts of Appeals for the Second and Seventh Circuits, respectively, followed the Supreme Court’s more than century old decisions that had ruled, in the words of Heller’s Footnote 23, “that the Second Amendment applies only to the Federal Government.”

Thus, last week, after the Seventh Circuit rejected incorporation of the Second Amendment in the challenges to the Chicago-area gun restrictions, two petitions were filed with the Supreme Court to get it to resolve once and for all whether “the right of the people to keep and bear Arms[ ] shall not be infringed” from coast-to-coast -- or only where the federal government is the only power-that-be.

Needless to say, the likelihood that the justices will take up the issue during their next term, which begins on the first Monday of next October, is exceptionally high. After all, right now Americans find themselves in the ridiculous position of possessing Second Amendment rights if they happen to be in D.C. or any of the nine states and two territories of the Ninth Circuit, while not possessing those same constitutional rights if they are in any of the six states of the Second and Seventh Circuits. In the rest of the states, no one really knows whether the Second Amendment applies because the other federal appellate courts have not addressed the issue since the Supreme Court decided Heller last June.

The long and short of all this is that the Heller ricochet has returned the Supreme Court, and hopefully by this time next year all of America will know for sure that the Second Amendment’s individual right to self-defense “shall not be infringed” anywhere in these United States. After all, America has only one Constitution that includes only one Second Amendment, and so “the right of the people to keep and bear Arms” should be the same nationwide.