In a closely watched case, the U.S. Court of Appeals for the Fourth Circuit issued a significant decision on March 21, in which it affirmed the ability of state law enforcement to limit the carrying of guns in public places. Reversing the decision of a federal district court in Maryland, the circuit court held that a requirement under Maryland law – that an individual demonstrate a “good and substantial reason” in order to qualify for a permit to carry a handgun in public – does not violate the Second Amendment.

Notably, the Fourth Circuit rebuked the district court for making a “trailblazing pronouncement that the Second Amendment right to keep and bear arms for the purpose of self-defense extends outside the home” and it advised courts that they should await direction from the U.S. Supreme Court before determining whether or to what extent the Second Amendment might protect the possession of firearms in public.

The decision confirms that reasonable restrictions on carrying of handguns in public are constitutional, even if they strictly limit the number of individuals who may carry a handgun. As the Fourth Circuit explained, “The State has clearly demonstrated that the good-and-substantial-reason requirement advances the objectives of protecting public safety and preventing crime because it reduces the number of handguns carried in public. That is, limiting the public carry of handguns protects citizens and inhibits crime.”

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