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 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.
In January 2026, the United States Court of Appeals for the Fourth Circuit issued a major ruling on the case.
The court:
The court allowed Maryland to restrict carry in certain “sensitive locations,” including:
These restrictions remain enforceable under current law.
The court reversed an earlier ruling that had blocked Maryland from banning carry in some locations, including:
This means the state can continue enforcing those restrictions for now.
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 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.
For Maryland residents:
Because the law continues to evolve, it is critical for gun owners to stay informed and receive proper training.
At Smith Creek Co., our courses cover:
Whether you are applying for an HQL or considering a Wear & Carry Permit, proper training ensures you understand both your rights and your responsibilities.