Major Update to Maryland Concealed Carry Law: What the Kipke Case Means
Maryland’s handgun carry laws continue to evolve following the Supreme Court’s landmark decision in New York State Rifle & Pistol Association v. Bruen. One of the most important ongoing challenges is the case Kipke v. Moore, which directly affects where licensed individuals can legally carry a firearm in Maryland.
For anyone considering a Wear & Carry Permit or completing Handgun Qualification License (HQL) training, understanding this case is important because it shapes the real-world rules for lawful carry.
The Case: Kipke v. Moore
The lawsuit, Kipke v. Moore, challenges several parts of Maryland’s 2023 firearm legislation that created a long list of locations where concealed carry would be prohibited.
The plaintiffs argue that many of these restrictions violate the Second Amendment as interpreted by the Supreme Court in the Bruen decision.
What the Fourth Circuit Decided
In January 2026, the United States Court of Appeals for the Fourth Circuit issued a major ruling on the case.
The court:
Upheld Maryland carry bans in some places
The court allowed Maryland to restrict carry in certain “sensitive locations,” including:
- Government buildings
- Schools and school grounds
- Healthcare facilities
- Mass transit facilities
- State parks and forests
- Museums
- Stadiums and amusement venues
These restrictions remain enforceable under current law.
Reinstated carry bans in other areas
The court reversed an earlier ruling that had blocked Maryland from banning carry in some locations, including:
- Public demonstrations
- Businesses that sell alcohol for on-site consumption (RESTAURANTS)
This means the state can continue enforcing those restrictions for now.
Struck down one major restriction
The court affirmed the lower court’s decision that Maryland cannot automatically ban carry in private businesses open to the public unless the owner gives consent.
Maryland’s original law required explicit permission from the property owner before a firearm could be carried in many public-facing private locations.
The court ruled that restriction could not be enforced.
This portion of the decision is one of the most significant outcomes of the case.
The Case Is Not Over
The plaintiffs plan to ask the Supreme Court of the United States to review the case.
A petition for certiorari is expected, and the mandate from the Fourth Circuit has been temporarily stayed while the courts consider next steps.
If the Supreme Court accepts the case, it could further define the limits of “sensitive place” firearm restrictions nationwide.
What This Means for Maryland Gun Owners
For Maryland residents:
- You still need a Wear & Carry Permit to legally carry a handgun.
- Many location-based restrictions remain in effect.
- Some restrictions on private property have been struck down.
- The legal landscape may change again if the Supreme Court reviews the case.
Because the law continues to evolve, it is critical for gun owners to stay informed and receive proper training.
Training Still Matters
At Smith Creek Co., our courses cover:
- Maryland firearm law
- Safe handgun handling
- The HQL licensing process
- Real-world legal responsibilities for firearm owners
Whether you are applying for an HQL or considering a Wear & Carry Permit, proper training ensures you understand both your rights and your responsibilities.