Two years ago, America's highest judicial body declared in New York State Rifle & Pistol Association v. Bruen that gun restrictions must be analogous with rules which existed when the Constitution was ratified.

However, a subsequent decision released this past June has left some judges begging the Supreme Court for guidance. 

Justices found that domestic abusers can be barred from owning guns

In United States v. Rahimi, eight out of nine justices agreed that lawmakers can prohibit domestic abusers from possessing firearms.

When writing his majority opinion, Chief Justice John Roberts insisted that prior rulings on the Second Amendment "were not meant to suggest a law trapped in amber."

Rather, judges should instead consider "whether the new law is 'relevantly similar' to laws that our tradition is understood to permit, applying faithfully the balance struck by the founding generation to modern circumstances."

Roberts explained that "if laws at the founding regulated firearm use to address particular problems, that will be a strong indicator that contemporary laws imposing similar restrictions for similar reasons fall within a permissible category of regulations."

Federal judge says gun cases present lower courts with "a labyrinth"

The chief justice noted how early English and American "firearm laws have included provisions preventing individuals who threaten physical harm to others from misusing firearms."

Roberts argued that these examples "confirm what common sense suggests: When an individual poses a clear threat of violence to another, the threatening individual may be disarmed."

Yet as The New York Times reported this week, the situation remains far from clear for some jurists, including Fourth Circuit Chief Judge Albert Diaz.

He recently complained that the current situation has created "a labyrinth for lower courts, including our own, with only the one-dimensional history-and-tradition test as a compass."

"Courts, tasked with sifting through the sands of time, are asking for help," the Obama-appointed judge went to lament.

Law professor believes the Supreme Court will have to provide clarity

Meanwhile, Pepperdine University law professor Jacob D. Charles told the Times that it is likely only a matter of time before the Supreme Court once again weighs in on gun rights.

"Several major Second Amendment issues have been fracturing lower courts that may soon elicit Supreme Court review," Charles noted.

These include laws which bar felons, minors, and drug users from possessing weapons along with the constitutionality of gun-free zones and bans on certain types of semiautomatic rifles.