In a new law review article, retired U.S. Supreme Court Justice John Paul Stevens made a glancing reference to current-day partisanship, and reiterated his view that the Second Amendment pertains to regulated militias, not to an individual right to bear arms.

Stevens, active at age 99, made the remarks in the latest edition of the Michigan Law Review, reviewing a 2017 biography of James Madison by Harvard Law School professor Noah Feldman, titled “The Three Lives of James Madison: Genius, Partisan, President.”