[6] The term "bearable arms" was defined in District of Columbia v. Heller, 554 U.S. 570 (2008) and includes any ""[w]eapo[n] of offence" or "thing that a man wears for his defence, or takes into his hands," that is "carr[ied] .

[3] Justice Alito characterized the per curiam decision as "grudging" and wrote that "[t]he reasoning of the Massachusetts court poses a grave threat to the fundamental right of self-defense".

[15] After concluding that the Massachusetts stun gun ban violates the Second Amendment, Justice Alito wrote: "if the fundamental right of self-defense does not protect Caetano, then the safety of all Americans is left to the mercy of state authorities who may be more concerned about disarming people than about keeping them safe".

[17] In a subsequent case, Ramirez v. Commonwealth, the Massachusetts Supreme Judicial Court relied on Caetano to strike down the state's stun gun law.

[22] However, given the limited nature of the per curiam opinion, Denniston noted that "[t]he facts in this case do not necessarily stand as a definite constitutional declaration".