According to the Centers for Disease Control and Prevention (CDC), nearly 47,000 people died of gun-related injuries in the United States in 2023. Despite this litany of violence, gun control in the United States has become far more difficult. In 2008, the Supreme Court drastically reinterpreted the Second Amendment in District of Columbia v. Heller. Since then, the Court has enthusiastically expanded this newly discovered doctrine to strike down gun regulations. Congress, however, still has the ability hold gun sellers and manufacturers liable for gun violence.