ANNAPOLIS, MD — A divided panel of the U.S. Court of Appeals for the Fourth Circuit issued a decision on January 20, 2026, largely upholding Maryland’s 2023 gun control law restricting where legally armed citizens may carry firearms. The court sided with the state on bans targeting carry in sensitive locations such as government buildings, public transportation, schools, health care facilities, parks, and places serving alcohol — but ruled that the state’s blanket ban on carrying firearms on private property open to the public is unconstitutional .
The court’s ruling consolidated multiple lawsuits filed by individuals and gun rights organizations including Maryland Shall Issue, the Second Amendment Foundation, Firearms Policy Coalition, and others, who challenged Maryland’s Senate Bill 1. The plaintiffs argued the law violated the Second Amendment by dramatically reducing the number of public places where a permit holder could legally carry.
The panel, led by Judge Roger Gregory, applied the Supreme Court’s 2022 New York State Rifle & Pistol Association v. Bruen decision, which requires firearm regulations to be consistent with the nation’s historical tradition of gun laws. In the 94-page opinion, the court found that bans on carry in locations like schools, hospitals, and public transit fall within this historical tradition of regulating firearms in so-called “sensitive places” .
Among the locations where Maryland’s restrictions were upheld:
• Government Buildings
• Public Transit Systems
• Public and Private School Grounds
• State Parks, Forests, and Chesapeake Forest Lands
• Health Care Facilities
• Museums, Stadiums, Racetracks, Amusement Parks, and Casinos
• Locations That Sell Alcohol for On-Site Consumption
• Areas Within 1,000 Feet of a Public Demonstration After Law Enforcement Notification
However, the court struck down the state’s prohibition on carrying firearms on privately owned property that is open to the public — such as stores and parking lots — unless the owner posts explicit permission. The court determined that this provision imposed a broad and unjustified burden on the right to carry and failed to meet the historical standard required under Bruen .
The decision drew partial dissents, particularly from Judge Agee, who disagreed with the majority’s endorsement of certain location-based restrictions like public transit and amusement venues. But all three judges agreed on the unconstitutionality of the private property carry ban.
Following the ruling, Governor Wes Moore released a statement calling the decision “a major win for public safety,” emphasizing that the court “affirmed what common sense — and our Constitution — already makes clear: we can protect the Second Amendment while also protecting Marylanders from the heightened dangers of guns in places like schools, hospitals, public transportation, parks, and other spaces where families should be able to live, learn, and move about safely.”
While the Governor lauded the ruling, the court’s rejection of the private property restriction marked a clear win for gun rights advocates. Maryland Shall Issue and others are expected to continue challenging remaining provisions.
This case is likely not the final word. Given the significance of the constitutional questions and the split in reasoning, further appeals — including a possible petition to the U.S. Supreme Court — remain possible.
The court’s decision serves as a pivotal application of the Supreme Court’s evolving Second Amendment jurisprudence post-Bruen, reinforcing that while governments may restrict firearms in genuinely sensitive places, overbroad or poorly justified bans will not survive constitutional scrutiny.
Maryland’s continued effort to restrict where lawful citizens may carry has now faced its first major test under Bruen, and while the state succeeded in defending many of its provisions, it could not justify the blanket prohibition on public carry across all private property. The ruling affirms that while some carry restrictions are allowed, the state must meet a high bar in demonstrating historical analogues. For responsible gun owners, this decision reinforces both the importance and the limits of the right to bear arms in public.
