Supreme BDS

A subtle bit of BDS in the Heller Supreme Court arguments:

"MR. DELLINGER: I don't dispute, Mr. Chief Justice, that the Second Amendment is positive law that a litigant can invoke in court if a State were to decide after recent events that it couldn't rely upon the Federal Government in natural disasters* and wanted to have a State-only militia and wanted to have everybody trained in the use of a weapon, a Federal law that interfered with that would be a law that could be challenged in court by, by an individual."

Which natural disaster could Mr. Dellinger be referring to?

It seems that local governments have been far more abusive during natural disasters than the federal government.

(emphasis mine)