Actually, Miller was even more in tune with a proper reading of the Second Amendment than that.
The District Court originally dismissed the charges against Miller and his co-defendant Layton, simply citing the Second Amendment.
It was the prosecution who appealed and the Supreme Court accepted a direct appeal, bypassing the Circuit Court of Appeals.
The Supreme Court's ruling in Miller REJECTED the collective-right nonsense. What the Court did say was that they had no evidence to indicate whether a short-barreled shotgun was useful to a Militia, mainly because no trial had ever been held.
The Supreme Court reversed the District Court's dismissal and REMANDED the case back to that lower court. The intention was to have the trial court determine whether a short-barreled shotgun was useful to a Militia. Since short-barreled shotguns had been used in World War I, the so-called "trench gun", it would have been a piece of cake to overturn the National Firearms Act of 1934. There would have been no expectation that Miller had to be a member of a "Militia".
Unfortunately, before any action took place in the lower court, Miller died and Layton evidently copped a plea so nothing further was done with the case; with the exception that every lower court after that seemed to claim that the Miller decision established that the Second Amendment protected only state-organized Militia's. The Supreme Court committed treason in later years by failing to take cases which would right this terrible wrong.
The syllabus for U.S. v. Miller, which was written by staffers rather than any of the justices, says that the Court found the Second Amendment only protects state militias; at least one lower court cases cites language which appears in the syllabus but not in the actual decision in finding that the Second Amendment only protects state militias. It is unfortunate that the U.S. Supreme Court has been unwilling to take cases which would overturn the syllabus.
First off, from what I've heard about the "Miller case" United States v. Miller , 307, U.S., 174 (1939), before the SCOTUS, was that Miller was acting Pro Se, and did not have the money necessary to file any brief(s).
Remember this would have been a time when just copying cost(s) would have been thousands of dollar's, think "mimeograph machine(s)." See https://en.wikipedia.org/wiki/Mimeograph.
I don't know if my thought's are correct (Apparently they are, just slightly different from what I stated above) Reference Miller having not responded to any of the filings @ the SCOTUS, but maybe some else can add some information.
From http://encyclopediaofarkansas.net/encyclopedia/entry-detail.aspx?entryID=4742
5th (Fifth Paragraph) "Gordon Dean argued United States v. Miller et al. before the Supreme Court on March 30, 1939.
Defense counsel Gutensohn did not appear, sending a telegram to the Court on March 28, stating that his clients had been unable to pay him for his services."