And the Ninth Circuit has upheld section 5861 in the face of a second amendment argument post-Heller. United States v. Hatfield, 376 Fed.Appx. 706, 707 (9th Cir. 2010).
But there is no indication that tasers or stun guns have some sort of "special propensity for unlawful use," Maloney, 351 F.Supp.3d at 236, or that these arms are so "dangerous and unusual" that they fall entirely outside the scope of the Second Amendment. See, e.g., United States v. Zaleski, 489 F. App'x 474, 475 (2d Cir. 2012) (summary order) (finding machine guns unprotected); United States v. Hatfield, 376 F. App'x 706, 707 (9th Cir. 2010) (memorandum) (finding a sawed-off shotgun to be a "dangerous and unusual weapon" unprotected by the Second Amendment); United States v. Tagg, 572 F.3d 1320 (11th Cir. 2009) (finding "pipe bombs" unprotected by the Second Amendment). Other courts considering statewide bans on electric arms have reached the same conclusion.
The overwhelming majority of courts that have addressed Second Amendment challenges have found that the weapon's "typical possession" for an unlawful purpose, in itself, is sufficient to deny Second Amendment protection. See, e.g., Kolbe, 849 F.3d at 131 (noting that even if the majority accepted the dissent's argument that assault weapons are popular, the Court can still "stop those weapons from being used again and again to perpetrate mass slaughters"); Friedman v. City of Highland Park, Illinois, 784 F.3d 406, 408-09 (7th Cir. 2015) (noting that "during Prohibition the Thompson submachine gun (the 'Tommy gun') was all too common in Chicago, but that popularity didn't give it a constitutional immunity from the federal prohibition enacted in 1934"); United States v. Hatfield, 376 F. App'x 706, 707 (9th Cir. 2010) (holding that "modern sawed-off shotguns are not typically possessed for lawful purposes" and, therefore, are not entitled to Second Amendment protection); United States v. Marzzarella, 614 F.3d 85, 95 (3d Cir. 2010) ("It is arguably possible to extend the exception for dangerous and unusual weapons to cover unmarked firearms. . . . Because a firearm with a serial number is equally effective as a firearm without one, there would appear to be no compelling reason why a law-abiding citizen would prefer an unmarked firearm. These weapons would then have value primarily for persons seeking to use them for illicit purposes."); United States v. Tagg, 572 F.3d 1320, 1326 & n.5 (11th Cir. 2009) ("[W]e conclude that the pipe bombs at issue were not protected by the Second Amendment.