While a majority of states require an individual to meet only minimal requirements to acquire a license to carry a loaded, concealed firearm in public, California and New Jersey both require an individual to show a justifiable need to acquire such a license. Individuals in both states who were denied licenses argued that these requirements violated the Second Amendment in Piszczatoski v. Filko and Birdt v. Beck.

The federal courts in New Jersey and California found these state laws constitutional, concluding that the use of standards in limiting who may carry concealed handguns helps protect law enforcement officers and members of the public from the dangers posed by guns in public places. As these cases and others have repeatedly shown, the Second Amendment is consistent with a wide variety of sensible gun laws that help protect public safety.