You may recall that the Heller decision held that the category of "arms" that are protected by the Second Amendment are those in common use. So what does that include? It appears, from this new survey, that this includes AR-15 pattern rifles:
The first comprehensive survey to look at ownership and use of modern sporting rifles reveals that 8.9 million Americans went target shooting with AR-style rifles in 2009 and that participants using this type of rifle were the most active among all types of sport shooters.Let's see: that's about 3% of Americans went target shooting with AR-style rifles last year. Larger numbers doubtless own such rifles but did not go target shooting last year. Me, for example. I didn't take my AR-15 target shooting last year--and there are doubtless others in the same category as myself.