U.S. v Miller said a sawed off shotgun didn't deserve protection under the 2nd amendment because it didn't have a military use. (Based on that argument, Military style AR rifles should receive the most 2nd amendment protection)
Edit: the quote from US v Miller is:
In the absence of any evidence tending to show that possession or use of a 'shotgun having a barrel of less than eighteen inches in length' at this time has some reasonable relationship to the preservation or efficiency of a well regulated militia, we cannot say that the Second Amendment guarantees the right to keep and bear such an instrument. Certainly it is not within judicial notice that this weapon is any part of the ordinary military equipment or that its use could contribute to the common defense. Aymette v. State of Tennessee, 2 Humph., Tenn., 154, 158.
It didn't use the collective rights argument, or it would have just said Miller, a criminal gang member, was not part of a well regulated militia and had no 2nd amendment rights.
The text of U.S. v Miller is online to read. There were lower court decisions that endorsed the collective right interpretation that essentially removes the 2nd amendment from the constitution, but U.S. v Miller didn't explicitly support that.
None of the justices in U.S. v Heller, including both dissents, endorsed the collective right interpretation because it's not a sensible way to read the constitution. Something like Breyer's undue burden standard, but a remaining recognition of the individual right, is more likely even if a liberal SCOTUS decides to replace Heller.
