Key Takeaways
- A federal judge upheld Maryland’s ban on Glocks and striker-fired handguns, allowing it to take effect on January 1, 2027.
- Judge Richard D. Bennett denied the plaintiffs’ request for a preliminary injunction, stating that the law aligns with Second Amendment regulations.
- Senate Bill 334 prohibits the sale and transfer of machine gun convertible pistols, including Glocks, due to potential modifications into fully automatic weapons.
- The ruling underscores that the state justifies this ban as a necessary response to advances in weapon technology and rising gun violence.
- The case is ongoing, and the judge suggested that the challengers were unlikely to win, which led to the denial of the emergency order.
Estimated reading time: 6 minutes
BALTIMORE, MD — A federal judge has refused to block Maryland’s ban on the sale of Glocks and other striker-fired handguns, leaving the law on track to take effect January 1, 2027, while the lawsuit against it continues.
U.S. Senior District Judge Richard D. Bennett denied the plaintiffs’ request for a preliminary injunction in a memorandum opinion filed October 5 in the U.S. District Court for the District of Maryland. A preliminary injunction is an emergency order that would have stopped the state from enforcing the law while the case plays out. Bennett ruled from the bench against the challengers at a September 25 hearing and issued this written opinion to explain his reasoning. The challengers are a deep bench of gun owners, dealers, and 2A groups, including the National Rifle Association, the Firearms Policy Coalition, the Second Amendment Foundation, Maryland Shall Issue, and Atlantic Guns. NRA-ILA tracked the bill through the General Assembly in April and called it what it is, a semi-auto ban.
The bill text is where the Glock ban actually lives. Senate Bill 334, signed by Governor Wes Moore and codified as Chapter 771, prohibits manufacturing, selling, offering for sale, purchasing, receiving, or transferring a “machine gun convertible pistol,” subject to narrow exceptions. The statute defines that as “any semiautomatic pistol with a cruciform trigger bar that can be readily converted by hand or by using common household tools into a machine gun by the installation or attachment of a pistol converter as a replacement for the slide’s backplate.” A cruciform trigger bar, under the law, is a component that links the trigger to the firing pin and has its sear built into a cross-shaped surface. That is the design behind Glocks and the Glock-style pistols the ban reaches. Violating it is a misdemeanor punishable by up to three years in prison and a fine of up to $5,000.
The law even spells out what counts as a common household tool: a screwdriver, a pipe wrench, pliers, a hacksaw, a crowbar, an electric drill, a rotary tool, a hammer, a chisel, a file, and a crescent wrench. The state is not banning a machine gun. It is banning a semiautomatic pistol because someone with a screwdriver and an illegal part could turn it into one.
Bennett’s analysis ran through the Supreme Court’s Bruen framework, which asks two questions. First, does the law touch conduct the Second Amendment’s plain text covers? If it does, the burden shifts to the state to prove the regulation fits the nation’s historical tradition of firearm regulation. Bennett found that machine gun convertible pistols, which include popular Glock and Glock-style handguns, likely do fall within the plain text, because handguns are what the Supreme Court has called the quintessential self-defense weapon. That gets the challengers past step one.
Step two is where they lost. Bennett held that Maryland carried its burden by showing SB 334 is “consistent with restrictions on excessively dangerous weapons which have been regulated in response to their criminal misuse and lethality.”
“Machinegun convertible pistols, which can be modified into combat weapons with the insertion of a 3D printed device, implicate technological advances our founders could not have foreseen,” Bennett wrote. “The State has submitted historic evidence supporting that SB 334 is a commensurate response to the advances and to today’s unrelenting tide of mass shootings and gun violence.”
To get there, Bennett leaned heavily on the Fourth Circuit’s en banc decision in Bianchi v. Brown, the ruling that upheld Maryland’s assault weapons ban. An en banc decision is one issued by the full appeals court rather than a three-judge panel, which makes it binding and hard to dislodge. Once the appeals court that governs Maryland has blessed a ban on semiautomatic rifles as fitting a tradition of regulating weapons with a “potential for widespread criminal abuse or unreasonable capacity to inflict casualties,” extending that reasoning to a semiautomatic handgun is a short step, and Bennett took it. He quoted Bianchi’s line that “these are not our forebears’ arms, and these are not our forebears’ calamities.”
The switches that make a Glock fire full-auto are already illegal to possess, and modifying the pistol is already a crime. SB 334 adds nothing for the criminal who does the converting. It takes the pistol off the shelf for the lawful buyer who never would. If you hold a Maryland wear and carry permit and your carry gun is a Glock, this law decides what you can buy in-state once it takes effect, and this ruling means it keeps deciding for now.
The mindset point is simple. The pistol in a law-abiding citizen’s holster is the same hardware the day it is bought and ten years later. The state’s theory is that what some criminal could do to it with a screwdriver makes it too dangerous for you to own. If that reasoning holds, I do not see an obvious limit to it, and the Fourth Circuit has already shown it is willing to let it hold.
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This was a ruling on the injunction only, not a final judgment. Bennett found the challengers had not shown they were likely to win, which under the governing test was enough to deny the emergency order on its own. The case continues toward the merits, and any appeal lands back in the Fourth Circuit, the same court that upheld Maryland’s assault weapons ban.
I will continue tracking the challenge to SB 334 as it moves through the District of Maryland.
Legislative data provided by LegiScan (CC BY 4.0, legiscan.com).
