A higher court writes a decision which says X. Misreading the case, many lower courts claim that the decision means Y. Years later, the higher court faces the same issue. To what extent, if any, should the higher court's new decision take into account the reliance interests of the lower courts who said Y?

Is the obvious answer "none"? Justice Stevens and the other three dissenters in Heller did not think so. All nine Justices agreed that the Second Amendment secures an individual right, not a collective right. (The Justices disagreed about the scope of the individual right--in effect, a disagreement between X1 and X2.) Yet Justice Stevens in dissent complained at length that the Heller majority was harming the reliance interests of lower courts, and his litany of complaint about lower court decisions that were being disregarded included many "collective right" decisions from the lower courts.

I am working on a law review article on the subject. I would be grateful for any leads for law review articles which discuss what deference higher courts should give to a large body of lower court decisions on an issue of law, particularly when that body of decisions is based on the lower courts' controversial application of a precedent from the higher court.