It goes back to 1939 at least, judging by this unanimous supreme court decision:

Justice McReynolds wrote..

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.

Complete and utter disregard for the definition of the word "infringe":

Second Amendment wrote..

...the right of the people to keep and bear arms shall not be infringed.

dictionary wrote..

infringe: v. to act so as to limit or undermine; to encroach on