The Strange Career of the Second Amendment, Part II

Jennifer Jopp

[The first part of this essay, in our previous issue (ATC 198, https://solidarity-us.org/atc/198/second-amendment/), explored the 18th and early 19th century origins of the conflict between “the importance of a militia to a free state” and the individual right to own and carry guns.]

AS STATES MOVED to ban concealed weapons and eventually to criminalize the possession of certain kinds of weapons, courts struggled to articulate which view of the right to bear arms — civic or individual — held sway. Court decisions articulating the view that the right encompassed an individual right were often met with consternation, and in general the public expressed the view that “the people’s right to be free from the threat of violence took precedence over the individual’s right to arm himself.”(1)

Yet the articulation of an individual rights conception had been voiced and would gain adherents over time. Arguments in favor of an individual rights interpretation came from two opposing — yet interrelated — quarters: a growing critique of slavery and its endemic violence and the growing grip of cotton production on the slaveowning southern states.

The abolitionist movement grew out of a heady mixture of the revolutionary era’s language against slavery, the impact of the second religious Great Awakening’s powerful impetus to purify society and in response to the growing power of slavery in the American economy and society. As abolitionist thinking developed, it came to articulate a radical critique of American society and law.

Many abolitionists, such as John Brown, came to believe that the violence of slavery could only be met with violence on the part of abolitionists. The conflict in Kansas and the murder of abolitionist activists as well as the violence of the slave system itself, led many in the movement to assert that arming Blacks — slave and free — was the only way to end slavery.(2)

In these decades, militias in the South functioned largely as slave patrols or provided the personnel for slave patrols. Cadets from state-funded military academies like Virginia Military Institute and The Citadel — founded to provide the military discipline and command structure necessary to police slavery — also filled the ranks of the patrols.

Slave codes made the white male population responsible for policing the Black population, both slave and free. Patrols were given extensive legal authority to ask any Black person for a pass, to enter any dwelling or to mete out any punishment. State and local laws targeted Blacks for disarmament.

Other groups in American society were also targeted for disarmament. The Indian Intercourse Act of 1834 forbade selling weapons of any kind to indigenous peoples. In these decades, free Blacks, Catholics, and those born outside the United States were all at various times forbidden from carrying guns.

Disarmament, it is worth remembering, came within the context of resistance to the contemporaneous and interrelated processes of dispossession of indigenous lands (accelerated by the Indian Removal Act of 1830) and the expansion of the plantation economy. Throughout the South, the building of arsenals, the creation of military academies, the expansion of the state militias, as well as increasingly draconian slave codes, came in the aftermath of a series of slave revolts.

At the same time, the rights of white men to own guns expanded. Of the 20 states joining the Union between 1790 and 1860, 14 included provisions for the right to bear arms. This development paralleled others of the time period; it was also during these decades that the rise of universal white manhood suffrage meant the demise of voting rights for women and free Blacks.

New technological developments meant smaller weapons and — in an increasingly anonymous society — posed a particular sense of danger and spurred a series of state regulations on carrying weapons. As states sought to regulate guns, arguments advancing an individual right to arms appeared.

This emphasis reflects an emerging set of ideas in the early national period that mirrors other developments in the law. A growing emphasis on the desirability of competition and the demise of an emphasis on the rights of the community appeared in many aspects of the law.(3) Nineteenth century society was rife with violence: street brawls, riots, and fisticuffs were commonplace.(4)

As did the Revolutionary War, subsequent wars raised questions about the nation’s military preparedness and prowess. The War of 1812 brought new concerns about the weaknesses of the militia system and new support for a stronger Navy and Army.(5)

Questions about the efficacy of militias were also raised in response to periodic revolts. The hostility to centralized authority that earlier rebellions had articulated never disappeared (and never has disappeared) from American life. The 1842 Dorr Rebellion, as one example, raised the question of the right of revolution inherent in a republican form of government and the rebels formed their own militia units and sought to seize weapons from a public arsenal. The state militia quickly put down the rebellion.

Among the transformative aspects of the Civil War was the arming — as government policy — of Black men as soldiers in service to the republic. One of the central challenges of Radical Reconstruction in the years after the Civil War was the demand of newly freed Black men for the rights of citizenship. As Martha Jones aptly illustrates, the demands that shaped post-bellum debates had been nurtured in the decades before the war as free Blacks developed an argument for birthright citizenship, the right to serve on juries and the right to carry weapons.(6)

Indeed, Jones suggests that the denial of citizenship rights to Blacks, and the ways in which they are spelled out in the earlier Dred Scott decision, was formulated in response to demands by free Blacks in the era between the Revolution and the 1856 decision.(7) The decision noted that conceding that Blacks were citizens would include the “right to keep and carry arms wherever they went.”(8)

There is thus a long history of efforts to keep weapons out of the hands of Black men. The regulations designed to do so often came in the aftermath of slave revolts or uprisings. After the Haitian Revolution, which reverberated throughout the Atlantic slave world, the first U.S. official to take control of the new American possession of Louisiana ceded to the planters’ demands to disarm existing Black militias.

In many states, laws were passed in the aftermath of slave revolts to remove access to guns by free Black men. For example, free Blacks in Baltimore, though subject to licensing rules, had had access to gun ownership.(9) Attempts to restrict that access was understood, by both the whites who sought the restrictions and the Blacks who fought for access, as a question of citizenship and rights.

That connection was further complicated by the double purpose for which guns could be put: self-protection and hunting. Hunting offered food, items for trade and a measure of independence.(10) This quest for autonomy was understood by slave owners who sought to restrict Black men — slave and free — from having guns. Naturally, too, armed Blacks could fight back and defend themselves.

John Brown was one abolitionist who clearly understood this connection and devoted many of his efforts to the arming and training of Black men. One aspect of the fundamental terror that he struck in the hearts of slaveholders was certainly the prospect of armed Blacks who could defend themselves and could aid slaves in running away or preventing recapture by slave patrols.

Black men trained in military tactics could also potentially recruit and train others, no small fear in the uneasy borderlands of Florida and Texas. In the wake of Nat Turner’s rebellion, as one example, the state of Virginia prohibited free Blacks “to keep or carry any firelock of any kind, any military weapon, or any powder or lead.”

Tennessee altered its state constitution in 1834 to specify that the “white freemen of this State have a right to keep and bear arms for their common defense,” while an earlier provision had not specified race. Likewise, the demise of post-Civil War Reconstruction brought the Black Codes and the rise of the Ku Klux Klan, which both shared the goal of allowing the white populace to terrorize and police the Black population, including the goal of disarming Blacks.

The enactment of Black Codes throughout the South, limiting the civil rights of the new freedmen, including the right to own firearms, helped to spur passage of the Fourteenth Amendment. Many of its framers hoped that the amendment would require Southern states to extend the protections of the Bill of Rights — including the Second Amendment — to Blacks.

This issue was of particular import in the violence-ridden post-war South. It is also worth noting that at the end of the war, soldiers — including those of the defeated Confederacy — were allowed to return home with their weapons. There was a particular antipathy to the Republican plan to allow newly-freed Blacks to join state militias.

Subsequent decisions by the Supreme Court, most notably in the Slaughterhouse cases and in Cruikshank, severely limited the radical promise of the post-bellum amendments to the Constitution. Although there is substantial evidence that the Privileges and Immunities Clause of the Fourteenth Amendment was meant to protect the right of individuals to keep and bear arms from infringement by the states, the Supreme Court rejected this interpretation in United States v. Cruikshank (1876).(11)

Thus, throughout the 19th century the Supreme Court ruled that the Second Amendment does not bar state regulation of firearms. In Presser v. Illinois, the Court reiterated in 1886 that the Second Amendment is “only a limitation upon the power of Congress and the National government, and not upon that of the States.”(12)

Following the Civil War, Union veterans William Conant Church and George Wood Wingate created the National Rifle Association. They had observed that the absence of a powerful military culture in the North meant that Union soldiers were far less effective marksmen than their Confederate counterparts.

This concern was echoed in the 1901 creation of the National Board for the Promotion of Rifle Practice and in the 1903 Civilian Marksmanship Program. This latter program, part of a War Department appropriations bill, reflected a desire to improve military marksmanship and national defense preparedness. Participants in this federally funded program practiced marksmanship using surplus military weapons.

Likewise, concerns about the viability of the militia in the modern period led to the Dick Act of 1903 and the National Defense Act of 1913. These two acts nationalized the militia and brought it under federal control by creating the National Guard.

As noted above, gun regulations were often used to target “suspect” groups. The 1911 Sullivan law in New York required a license for any weapon small enough to be hidden. Evidence suggests that this law targeted Italian immigrants in New York City.

World War I and the military service of millions of young men brought yet another surge of racial violence in the aftermath of the war. Race riots that broke out in this era are some of the most violent in U.S. history.

Young Black men who had served in the armed forces and experienced unsegregated societies abroad returned home with a determination to live new lives. In reaction, white veterans “led second-era Klan efforts to violently ensure ‘all-American’ racial, religious, and nationalist power.”(13) Black men in uniform provoked particular animus.

Another aspect of the post-WWI culture of the United States was the rise of other forms of reactions against the cultural and social changes wrought by urbanization and the growth of an industrial society. These reactions found expression in the growth of Christian fundamentalism and their networks of radio stations, schools and other institutions, particularly in the aftermath of the 1924 Scopes Trial.(14)

The National Origins Act of 1924, severely restricting Asian and southern and eastern European immigration, was also another manifestation of the fear that white, rural Americans experienced in the face of the sweeping changes taking place in the country.

The 1930s, in response to an increase in organized crime, saw the passage of both the National Firearms Act of 1934, which required taxation on and registration of automatic weapons, and the Federal Firearms Act of 1938.

In the 1939 Supreme Court Case of United States v. Miller, a challenge to the National Firearms Act of 1934, the Court ruled that the Second Amendment protected only the citizen’s right to own those firearms that were ordinary militia weapons. This decision held the Act constitutional, and in its reading of the Second Amendment (in conjunction with the Militia Clause of Article 1, Section 8 of the Constitution), asserted that “[i]n the absence of any evidence to show that possession and use of a [sawed off] shot gun…has some reasonable relationship to the preservation or efficiency of a well regulated militia, we cannot say that the Second Amendment guarantees the right to keep and bear such an instrument.”(15)

World War II raised many of the same issues as had WWI: Black men and women, Native Americans, Japanese Americans and many others who fought for the United States fought in segregated units and faced hostility and discrimination.

The end of the war brought often violent confrontations between men in uniform and those desiring to maintain a racial status quo. “Third-era Klansmen,” men who had served in World War II and Korea, “played key roles in the violent opposition to civil rights.”(16)

Today’s paeans to Civil Rights leaders like Martin Luther King that focus on the language of his “I Have a Dream” speech, rather than his work with striking Memphis sanitation workers, elide the violence and brutality of the opposition to real racial equality in this country — then and now. Watching footage of white policemen standing by as protesters were beaten in Charlottesville last year was eerily reminiscent of so many episodes in the struggle for racial justice in this country.

When it came, once again, to the question of disarming Black men, the calculus is different. The NRA supported the Gun Control Act of 1968, which was certainly designed to remove weapons from the Black Panthers, who had openly displayed firearms.

It was in the 1970s, as noted above, when the NRA turned toward the view that it has increasingly embraced: any regulation on guns is an infringement of a constitutional right to the possession of guns. The subsequent Firearm Owners Protection Act of 1986 weakened provisions of the previous act and — responding to the NRA and other efforts — forbade the maintenance of a federal registry of gun ownership.

In 1980, the NRA for the first time endorsed a presidential candidate in Ronald Reagan. He appointed Antonin Scalia, who cast the deciding vote in District of Columbia v. Heller, the most important Supreme Court case dealing with the Second Amendment in decades.

There were certainly other forces at work in these years desirous of a change in both the public understanding of the Second Amendment and the law. John Ashcroft, Attorney General under George W. Bush, “took office with an agenda that included changing the Department of Justice’s position on the Second Amendment.”(17)

In Heller, the Supreme Court found that the Second Amendment protects an individual right to possess and carry firearms. It also ruled that two District of Columbia provisions, one that banned handguns and a second that required lawful firearms in the home to be disassembled or trigger locked, violate this right.

In arriving at its decision — using an “originalist” approach — the Court engaged in some interesting historical interpretation, citing language from circumstances that did not reflect the broad spectrum of opinion at the time. To cite an example, the Court cited the 1846 case of Nunn v. State, an 1846 Georgia case written by Joseph Henry Lumpkin.

Lumpkin, a staunch defender of slavery, struck down a gun law on the basis of the Second Amendment. In citing this case, while failing to explore contemporaneous gun regulations in many northern states, Heller moved a view of weapons use forged in the slave culture of the south as the legal norm of the country at the time.

In that period in the South, it was regarded as a question of honor to openly carry weapons and “this enthusiasm for public carry influenced its legal culture.”(18) No doubt, openly carrying weapons also increased the ability of slave patrols to exercise terror on the slave population. Thus, although this conception of the Second Amendment — as we have seen — has a racist history as old as the republic, it was now articulated by the highest court and had thereby given the NRA’s understanding of that history its imprimatur.(19)

This view of the Second Amendment was fertile ground for a growing strain of thinking in American culture. In the aftermath of the Vietnam War, a shattering military loss with which the country has yet to come to terms, a “lost cause” narrative had particular appeal to the white power movement. Many veterans “carried the war home” through engagement in paramilitary activity. In a twist on earlier versions of such movements, the state itself became the enemy.(20)

In many ways, this view of the state found an echo in much of the anti-statist rhetoric at all levels of American society. As the Republican Party began to openly deride the institutions of the republic and Reagan asserted that “the government is the problem,” large sectors of the population grew disaffected from the traditional organs of state: Congress, the presidency, the press, and the military.

For growing numbers of heavily armed white power groups, the events at Ruby Ridge (1992) and in Waco (1993) confirmed the narrative that the federal government was an oppressive occupying power. A fixation on outward enemies has meant that white nationalist and other hate groups in the United States have continued to grow, and the threat that they pose to the country has been generally ignored by the federal government, intelligence agencies, and law enforcement organizations.(21)

Of course, the rise of white power groups is only one part of a larger story about the omnipresence of guns in our society. So pervasive are they, and so potent their connection to ideas about masculinity and power, that it is often difficult for politicians to formulate an effective argument against their possession.

Many people “feel they’ve been the victims of sustained economic violence at the hands of tyrannical governments” of both parties. For many in rural America, on the losing side of globalization and its attendant deindustrialization, “protecting and expanding Second Amendment rights is the only policy that they’ve been able to get politicians to move on. For that reason alone, it’s totemic.”(22)

Ultimately both sides misstate the issues. The Second Amendment was not seen at the time as exclusively guaranteeing an individual right to bear arms as a right distinct from military service. It certainly had little to say about other forms of “gun control,” as it was common at the time for regulations on everything from where one could store gunpowder to who could possess a gun.

Thus, the phrasing is certainly not meant to mean that the right is unrestricted as it is understood in the modern sense. Yet liberals, too, misstate their case when they assert that the Amendment speaks only to a collective right to gun ownership. It was commonly understood at the time that English common law gave one the right to self-defense, and subsequent developments — especially in the 19th century — sharpened this strain of thinking in American culture.

True, for much of American history, the Second Amendment was understood to address a collective right to gun ownership. The NRA’s original motto was “Firearms Safety Education, Marksmanship Training, Shooting for Recreation.” Yet a strain of thinking articulating the idea of gun possession as an individual right, and as a means of protection of the home, has always existed alongside the collective understanding.

Today, the headquarters of the NRA contains this truncated inscription of the Second Amendment: “The Right of the People to Keep and Bear Arms Shall Not be Infringed.” The larger militarization of our culture as well makes gun possession difficult to discuss and an intractable problem to solve.

We live in a country awash with weapons. Surplus military weapons that can no longer be sold to our allies (and enemies) abroad wind up in the hands of gun enthusiasts and local police forces. The post 9-11 arming of the police with military grade weapons is a continuation of a long tradition of surplus weapons in the hands of civilian forces.

The United States is the most heavily armed society in the world, with 112 guns for every 100 citizens.(23) Almost a hundred people die every day in the United States by gunshot. We do not have access to complete information about the full impact of guns in our culture. The 1996 Dudley Amendment limits academic research into gun violence by controlling funding administered by the Centers for Disease Control: none of the funding can be invested in research that “may be used to advocate gun control.”

In our current political climate then, one might say that the oldest idea of all — that of an individual right to possess a weapon which cannot be taken away from you by the government — has gained new currency. In its newest incarnation, this idea has taken a new turn in its adherents’ insistence that the government has no right to regulate guns at all.

Such a belief signals the loss of a sense of the legitimacy of the government to rule and to regulate the lives of its citizens. Here we see once again the fault line of race in our history. For it was after the election of Barak Obama that this idea and the fear that the government would disarm the populace gained new currency. For adherents of white power ideas, the election of the nation’s first Black president spelled a world turned upside down.

The debate over the meaning of the Second Amendment — as do so many other contemporary debates — functions on multiple levels. On one level, it is a debate, however flawed, about reducing violence in our society. Proponents of forms of gun control who call for more regulation in the aftermath of every mass shooting do, indeed, want to reduce the incidence of gun violence in our society.

On another level, it is of course a debate about who we are as people, who we are as a society, about what our history says about us, and about how we understand public space in American society. The sites of much of the gun violence in our society — public schools and public lands — speak to our inability to come to terms with the human costs of our militarized culture.

The armed takeover of Malheur Wildlife Refuge in Oregon by white men claiming ownership of land, land now deemed to be “public” although once in the hands of indigenous peoples, speaks to the ways in which the government has lost its legitimacy in the eyes of part of the populace. The failure of the federal government to call these actions treasonous speaks as well to the erosion of the government’s own sense of a loss of power.

The contrast of the public treatment of armed white men on public lands with the treatment of peaceful protesters at the Dakota Access Pipeline site also speaks to the ways in which this debate is — and always has been — racialized. The “right” to “keep and bear arms” for many is the right of white men of all classes to exercise their power and masculinity against all others in society.

We might better call a reckoning with our current history of guns “bringing the war(s) home,” as from the beginning of the republic we have never come to terms with war and its costs. Such a lack of acknowledgment might seem a strange fate for an imperialist power that, first with continental settler colonialism, then with imperial expansion in the Caribbean and Central America and the Philippines, and later as a global force has extended its military might and its destructive tools all over the world.

Yet from the earliest fear of the corrosive impact of paid mercenary soldiers, to Reagan’s assertion that we would help “no country that came to power by the barrel of a gun,” to our current attempt to keep men destroyed by the costs of war from public view, we fail to reckon with the costs of war.

From colonial conflict with Native Americans to the unspeakable violence of slavery to the Revolution, the conflict with the Barbary states, the War of 1812, the Mexican War, the Civil War, the Spanish American War, World War I, World War II, the Cold War, the Korean War, wars in Central America, the Iraq War, the war in Afghanistan, the war in Serbia, the Second Gulf War, the war in Yemen, the war in Libya, and the war in Syria, we must not imagine that we can live in a world steeped in death and destruction and not pay its costs.

From the outset, these wars have required men to kill, leading to difficulty in their returning to civilian life. In the aftermath of every one of these wars, we have veterans — many of them armed and trained in weapons’ use — who do not take easily to rule by others. We have always feared these men, feared their return to us, but not enough to give up war.

In the 20th century and continuing today, this tendency took on new urgency as we moved to a permanent military footing and a permanent military economy. Weapons production shapes our economy, our society, and our foreign policy. Trump’s boasted sale of $110 billion of weapons to the Kingdom of Saudi Arabia is only the latest example of the ways in which military imperatives overtake all other concerns, democratic or humanitarian.

We do not know what to do with all of the weapons that we produce, and thus we are awash in surplus weaponry. These weapons find their way into the hands of all kinds of people. Gun shows and shooting ranges offer one avenue of access. Vast stores of weapons are also the target of large-scale theft; we do not have an effective system for tracking all of the weapons that exist in this country.(24)

We live in a society steeped in a violence that is elided from much of our history. We believe ourselves to be, we want to be, a country that is guided by the “better angels of our nature.” Yet we are, as we have always been, a country unable to free itself from the clutches of our past as a society founded on a particularly potent mix of settler colonialism, slavery, and a messianic sense of purpose.

It is also a violence that is disproportionately borne by the poor and people of color in our society, yet for which we all pay a price. Our increasingly militarized police forces, our militarized carceral state, militarized borders, and vast military-industrial and financial complex threatens us with ever intensifying carnage.

We end where we began at the outset of this essay: Until the United States can come to terms with our violent history, until we disentangle the ownership of weapons from what it means to be a citizen in this country, we have little hope of solving the contentious debate on the Second Amendment.

Bibliography

There is a voluminous literature on the Second Amendment, below is a select bibliography:

Belew, Kathleen. Bring the War Home: The White Power Movement and Paramilitary America. Cambridge and London: Harvard University Press, 2018.

Bellesiles, Michael A. Arming America: The Origins of a National Gun Culture. New York: Vintage Books, 2000.

Charles, Patrick J. Armed in America: A History of Gun Rights from Colonial Militias to Concealed Carry. Amherst, New York: Prometheus Books, 2018.

Cornell, Saul. A Well-Regulated Militia: The Founding Fathers and the Origins of Gun Control in the United States. Oxford and New York: Oxford University Press, 2006.

Cress, Lawrence Delbert. Citizens in Arms: The Army and the Militia in American Society to the War of 1812. Chapel Hill: University of North Carolina Press, 1982.

Jones, Martha. Birthright Citizens: A History of Race and Rights in Antebellum America. Cambridge: Cambridge University Press, 2018.

Kristof, Nicholas. “Let’s Talk about the N.R.A.” The New York Times, Sunday, November 5, Week in Review: 4.

Ortiz, Roxanne Dunbar. Loaded: A Disarming History of the Second Amendment. San Francisco: City Lights Books, 2018.

Tushnet, Mark V. Out of Range: Why the Constitution Can’t End the Battle Over Guns. Oxford: Oxford University Press, 2007.

Williams, David. C. The Mythic Meanings of the Second Amendment: Taming Political Violence in a Constitutional Republic. New Haven and London: Yale University Press, 2003.

Winkler, Adam. Gunfight: The Battle over the Right to Bear Arms in America. New York and London: W.W. Norton & Company, 2011.

Notes

1. Cornell, A Well-Regulated Militia, 149.
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2. Reynolds, John Brown: The Man Who Killed Slavery, Sparked the Civil war, and Seeded Civil Rights (New York, 2005); James Brewer Stewart, Holy Warriors: The Abolitionists and American Slavery (New York, 1996).
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3. See Morton Horowitz, The Transformation of American Law (Cambridge and London: Harvard University Press, 1977).
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4. Joanne Freeman, The Field of Blood: Violence in Congress and the Road to Civil War (New York: Farrar, Straus & Giroux, 2018).
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5. Steven Watts, The Republic Reborn: War and the Making of Liberal America, 1790-1820 (Baltimore, Maryland, 1987).
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6. Martha Jones, Birthright Citizens: A History of Race and Rights in Antebellum America (Cambridge: Cambridge University Press, 2018).
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7. Ibid.
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8. Dred Scott v. Sanford, 19 How. (60 U.S.) 393 (1857).
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9. Jones, Birthright Citizens, 102.
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10. Jones, 104.
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11. United States v. Cruikshank, 92 U.S. 542, 553 (1875).
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12. Presser v. Illinois, 116 U.S. 252, 265 (1886).
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13. Kathleen Belew, Bring the War Home (Cambridge and London: Harvard University Press, 2018), 20.
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14. In a recent article on Truthdig, Paul Street, citing Jason Stanley’s How Fascism Works, listed some characteristics of our current political culture; many of these- including a loathing of cities and anti-intellectualism were also hallmarks of particular strains in American culture in the 1920s. See “Signs of Creeping Fascism all Around Us” on Truthdig, November 14, 2018. See Edward J. Larson, Summer for the Gods (Basic Books, 2006).
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15. United States v. Miller, 307 U.S. 174 (1939).
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16. Belew, Bring the War Home, 20.
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17. Mark Tushnet, Out of Range: Why the Constitution Can’t End the Battle over Guns (Oxford University Press, 2007), 1.
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18. Saul Cornell and Eric Ruben, “The Slave-State Origins of Modern Gun Rights,” The Atlantic, September 30, 2015.
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19. A more recent Supreme Court case addresses the long-standing reluctance of the Court to extend Second Amendment rights to the states through the Fourteenth Amendment; see McDonald v. City of Chicago, 561 U.S. 742 (2010).
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20. Belew, Bring the War Home, 24.
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21. Janet Reitman, “State of Denial,” The New York Times Magazine, Sunday November 11, 2018: 38-49; 66-68.
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22. Quoted in Roxanne Dunbar-Ortiz, Loaded: A Disarming History of the Second Amendment (San Francisco: City Lights Books, 2018), 104.
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23. Small Arms Survey.
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24. See Belew, Bring the War Home.
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March-April 2019, ATC 199