BELLEVUE, Wash. — July 23, 2026 — The Second Amendment Foundation (SAF) filed an amicus brief today in the Supreme Court of Maryland supporting the petition for certiorari in Darius Duvall v. State of Maryland, challenging the state’s refusal to recognize valid, out-of-state carry permits.
The brief urges the Court to grant review and hold that Maryland’s refusal to recognize these permits violates the Second Amendment. American historical tradition overwhelmingly protected travelers from other states, who were routinely exempted from state and local restrictions on the concealed carry of firearms. This “traveler’s exception” appears in Colonial-era laws, early 19th-century statutes from states like Kentucky, Indiana, Tennessee, Arkansas and Alabama, and continued after the Civil War in states including Nevada and California. More than 80 such historical examples have been compiled.
SAF is joined in the brief by Maryland Shall Issue, National Rifle Association, California Rifle & Pistol Association, Minnesota Gun Owners Caucus, Second Amendment Law Center, Citizens Committee for the Right to Keep and Bear Arms and the Cato Institute.
“History is clear: travelers from other states were given greater leeway to carry arms than residents,” said SAF Director of Legal Research and Education Kostas Moros. “Maryland’s modern scheme, which forces law-abiding adults who already hold permits from their home jurisdictions to jump through redundant and costly hoops or risk arrest, has no analogue in our nation’s historical tradition. The Supreme Court’s decisions in Bruen, Wolford, and Hemani require states to respect that tradition. The Court should grant the petition and put Maryland on the right side of the Second Amendment.”
The brief notes that Petitioner Duvall was arrested in Maryland while traveling and carrying with a valid District of Columbia permit. It contrasts Maryland’s total lack of any traveler exception with the historical pattern and emphasizes that the burden Maryland imposes is not comparable to any historical regulation.
“Our Second Amendment rights don’t end at state borders, and SAF is doing everything it can to push towards interstate carry rights in the courts,” said SAF founder and Executive Vice President Alan M. Gottlieb. “We forced California to begin issuing nonresident permits, and we will continue the fight until true permit reciprocity is the law of the land. Americans should not have to go unarmed when they cross an imaginary line just because lawmakers in certain states wish to see the Second Amendment relegated to a second-class right.”
