On behalf of several association of private security guards and detectives, and the Buckeye Firearms Foundation, a brief in DC v. Heller supplies the facts of the appalling mismanagement and institutional incompetence of DC's Metropolitan Police Department. Almost everyone who lives or works in the District of Columbia is well aware that the District's government performs very poorly compared to almost all other big-city governments in the United States. Nevertheless, the Buckeye brief is shocking.

The four core empirical subparts of the brief are titled: "The MPD Has A Significant Problem Hiring And Retaining Qualified Police Officers." "The MPD Has A Significant History Of Mismanagement." "The District's '911 System Is A Joke'." and "The MPD Has A Significant History Of Corruption." Every one of these points is proven beyond a reasonable doubt, relying almost entirely on reports in Washington newspapers.

Moreover, although paying for security, through a private security guard firm, is still legal in DC, the MPD controls the licensing of security guards, and works hard to suppress the private security business through licensing abuse, and by prosecuting security guards on specious charges.

The brief then points out that the DC government enjoys civil immunity from persons who are injured because the MPD's non-feasance, even when persons were injured because they relied on false promises from DC 911 operators that help was on the way.

Thus, the decent, law-abiding citizens of the District have no other recourse but to protect themselves (or to hire security guards, if the , and, the brief argues, the Court should recognize the right of the District's citizens to do so themselves.