From Prof. Glenn Reynolds’ "Second Amendment Penumbras: Some Preliminary Observations," commenting on the Supreme Court’s 2008 Second Amendment decision in District of Columbia v. Heller:
"The core of Heller is a constitutionalization of the right of self-defense. The right of individuals to protect themselves against violence is, in this analysis, so important that it is, in many ways, beyond the power of the state to regulate. Though the state might prefer to sacrifice citizens’ lives in order to limit gun ownership, such a sacrifice is not permitted. This indicates that individual citizens’ lives and autonomy are themselves, in some significant respects, beyond the power of the state to sacrifice. Does that have implications for other, unenumerated right? It just might."
Indeed. (You can retrieve and read Prof. Reynolds’ entire monograph HERE.)
