The left fires a counter-volley: meet the NRA's little-known, highly influential opponents.

IF there's one political group every American knows, and maybe fears a little, it's the National Rifle Association. As the Supreme Court gears up to hear arguments on the Second Amendment's meaning--in the context of the District of Columbia's firearm laws, which virtually ban handguns and require that long guns be "unloaded and disassembled or locked"--anyone on the street could tell you where the organization stands.

The NRA is known for pushing legislation and influencing elections, but few would be surprised to learn that it has funded research as well. In early 2003, it pledged $1 million for a Second Amendment professorship at George Mason University. It received $80 million in membership fees alone in 2004, and even some experts on the "anti" side say they're outgunned when it comes to influencing the courts.

No anti-gun organization is nearly as well known, but the NRAhas a counterpart: the Joyce Foundation, which at the end of 2006 had almost $1 billion in total assets. It has supported a broad range of gun-control efforts, from research to advocacy, and it approved more than $3.3 million in "gun violence" grants in 2006. Some of these grants have been ethically questionable; in just one example, at the beginning of this decade, a $900,000 donation to the gun-control panel of the National Academy of Sciences--to conduct a study for the government --raised eyebrows.

The Joyce Foundation has entered the Second Amendment-interpretation debate as well. There are two broad theories to choose from: The individual-right theory holds that American citizens have a right to own firearms for personal use. Collective-right theorists say the Constitution protects only states' rights to arm their own militias. The individual-right interpretation gained '80s and '90s, so Joyce began issuing grants for Second Amendment symposiums at law schools. The papers presented at these symposiums appeared in special issues of the schools' law reviews.

"The courts are looking at the whole body of scholarship, and presumably that will affect policies related to firearms," says Mary O'Connell, director of communications for Joyce. "For that reason it's of interest to us, but it's certainly not the center of our program."

These special law-review issues have disproportionately given voice to interpretations of the Second Amendment that would make it difficult for courts to strike down gun-control laws. This raises the question of whether law reviews--which rest their reputations on objectively considering each article's merits before publication --compromise their integrity when they participate in activist-funded events. In addition, two law-review issues did not disclose the grants.

The Joyce Foundation directly funded a symposium at the Chicago-Kent College of Law in 2000. Carl T. Bogus, a law professor who'd advised anti-gun groups including the Violence Policy Center (which has received more than $2 million from Joyce since 2003), edited the corresponding issue of Chicago-Kent Law Review. Introducing the symposium, Bogus wrote:

   With generous support from the Joyce Foundation, the Chicago-Kent
   Law Review sponsored this Symposium to take a fresh look at the
   Second Amendment and, particularly, the collective right theory.
   This is not, therefore, a balanced symposium. No effort was made to
   include the individual right point of view. Full and robust public
   debate is not always best served by having all viewpoints
   represented in every symposium. Sometimes one point of view
   requires greater illumination.

When the Ninth Circuit Court of Appeals took the collective-right view in 2002, the citation "76 Chi.-Kent L. Rev." appeared eight times.

In 2003, Joyce provided $400,000 to found the Second Amendment Research Center at Ohio State University's John Glenn Institute, through which it has dispensed its subsequent symposium money. History professor Saul Cornell, who heads the center, espouses a third, "civic-right" view, according to which the Second Amendment protects individual gun ownership, but only for the purpose of serving in a militia. The center itself takes no official position.

In 2004, Cornell and the Fordham Law Review co-hosted a symposium using funds from the Joyce Foundation. The "Editors' Foreword" to the symposium issue thanks Cornell for "conceiving of this Symposium, co-hosting it, and ensuring the participation and interest of such remarkable panelists." It makes no mention of the symposium's Joyce funding. Cornell's own article does note that "research support for this essay was provided by a grant from the Joyce Foundation." In 2006 Cornell's center co-hosted another symposium, at Stanford Law School, but the resulting issue of the Stanford Law & Policy Review similarly does not disclose the Joyce funding that made it possible--a $125,000 grant.

"Across the board, on all the different issues, there are foundations funding research. It's not the case that you're buying it," O'Connell says. "We did not decide who came to the symposiums, and we did not decide what articles ran."

Cornell says that his critics often misrepresent the symposiums, the latest of which, at Albany Law School, his center could afford to fund only partially. While some such events follow a "point-counterpoint" model, his have been dedicated to presenting new research. The individual- and collective-right theories have already been fleshed out in the literature, he says, so other theories tend to better fit this goal. "Joyce did not tell me I have to support the collective-right view," he says. "In fact, if you count up the articles, the collective-right view is the least represented. Most of the new scholarship has explored the middle ground--limited individual right, militia-based right, civic right, there are different ways to construe it."

He also notes that he has made efforts to include pro-gun voices. "I even asked the NRA for funding, but they haven't been forthcoming." For the Fordham event, "I went out of my way to find Calvin Massey, who took the individual-right view using arguments that hadn't been published before. I also invited some other people who turned me down." Still others attended the symposium but chose not to contribute articles for publication. "It's demonstrably false that those conferences were stacked," Cornell says.

Also, "I had no editorial function at all--the law-review editors called the shots," Cornell says. To the extent he had any control --as was the case, for example, with the event flyers--the funding was disclosed. "I was actually surprised that they didn't; your pointing it out to me was the first I remember noticing it," he says. He did not see the issues before publication.

John O. Enright, who was managing editor of the Fordham Law Review when the symposium issue ran, e-mailed NATIONAL REVIEW a statement on behalf of the review's editors at the time. He wrote that the law review itself "did not accept any funding for the Second Amendment symposium --our only role was to host the symposium on campus and edit and publish the papers submitted by the symposium's participants. (If any of the participants or their affiliated organizations received funding to take part in the symposium, we did not ask for or receive any part of that funding.)"

NR failed to reach the Stanford Law & Policy Review editors who worked on the issue, but the current editors in chief wrote in an e-mail, "We do not know whether SLPR then had a policy of not mentioning funding sources or whether the omission was inadvertent." The symposium was the third issue in Volume 17; the other volumes in the publication's archives contain at most two issues each.

On January 11 a group of historians, led by Bogus and including Cornell, filed a brief to the Supreme Court in support of the D.C. government, including citations to the Chicago-Kent symposium issue. The only funding for the brief itself came from Bogus's university research budget, according to the document.

It's unclear which way the court will go. After all, the lower courts are sharply divided--Fifth and D.C. Circuits on the individual side; Seventh and Ninth on the collective--and President Bush's recent appointments increase the likelihood of an individual-right ruling. But anti-gunners cannot plausibly claim their views have been underfunded or underrepresented in the scholarly literature--the infamous intermingling of "money and politics" (another of the Joyce Foundation's areas of interest) spills over into academia from both sides.