Estimated reading time: 4 minutes
Frustration is boiling over in the Second Amendment community after the U.S. Supreme Court declined to hear Gardner v. Maryland, a case widely viewed as one of the strongest challenges to the patchwork of concealed carry laws across state lines.
According to analysis from William Kirk of Washington Gun Law, the Court’s handling of the case left many wondering whether the justices are willing to step in at all as lower courts and state legislatures continue to test the limits of the Second Amendment.
And it’s not just the denial. It’s how the Court got there.
Table of contents
A Case That Had Momentum
At the center of the dispute was a Virginia resident, Ava Marie Gardner, a lawful concealed carry permit holder who found herself on the wrong side of Maryland law after a violent road rage incident.
According to Kirk, Gardner was forced off the road and confronted by an aggressive driver. After issuing verbal commands, she displayed her firearm to stop the threat.
Police responded. But the only person arrested was Gardner.
Not for assault. Not for brandishing. But for possessing a firearm in Maryland without the state’s carry credentials, despite being legally permitted to carry in Virginia.
That fact pattern is exactly why many saw this case as the perfect vehicle to address a longstanding constitutional question:
Does the right to carry a firearm stop at a state line?
The “Tease” Before the Denial
What has many in the 2A space especially frustrated is the timeline.
The petition was filed in October 2025. Initially, Maryland waived its response, which often signals a routine denial. But then something unusual happened.
The Supreme Court asked Maryland to respond anyway, triggering a wave of amicus briefs and renewed interest in the case.
Momentum built. Legal support grew. Expectations followed.
Then, after months of delay, including multiple extensions requested by Maryland, the Court reset the case for conference. And just days later, it was over.
Petition denied.
No explanation. No opinion. No guidance.
Growing Frustration With SCOTUS
For Kirk, the takeaway is clear and it’s not comforting.
“Am I going to sit here and tell you there’s some game of 4D chess going on?” he asked. “No, because the evidence just doesn’t suggest that.”
That sentiment is gaining traction.
The Court’s refusal to take up Gardner comes on the heels of other high-profile Second Amendment cases (like Snope v. Brown and Ocean State Tactical v. Rhode Island) where the justices also declined to intervene.
Meanwhile, lower courts continue to uphold restrictions, and states are moving forward with aggressive gun control measures.
Bigger Picture: A Court on the Sidelines?
The denial also lands at a time when new legislation, like the recently introduced Virginia Plan to Reduce Gun Violence Act of 2026, is pushing for sweeping federal restrictions.
At the same time, states like Rhode Island are exploring expanded bans that could include possession of previously legal firearms.
Put it all together, and the concern among gun owners is simple: If the Supreme Court won’t step in now… when will it?
Kirk points to the aftermath of the Court’s 2022 Bruen decision, when many believed stronger Second Amendment protections were on the horizon.
Instead, he argues, the follow-through hasn’t materialized.
What This Means Going Forward
Legally, the denial of Gardner v. Maryland Supreme Court changes nothing overnight.
There’s still no national standard for concealed carry reciprocity. Gun owners remain subject to a complex web of state laws that can turn a lawful act in one state into a criminal offense in another.
But politically and culturally, the impact is harder to ignore. The case had the facts. It had support. It had momentum. And still, the Court passed.
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Final Thought
For many in the 2A community, this wasn’t just another denied petition. It was a missed opportunity. And maybe a warning.
Because if cases like this aren’t enough to get the Supreme Court’s attention, the question becomes unavoidable: Is the Court waiting for the perfect case… or avoiding the issue altogether?
*** Buy and Sell on GunsAmerica! ***
is a seasoned outdoorsman, lifelong hunter, and the kind of guy who’d rather track whitetails than scroll social media. As an editor for GunsAmerica, he’s got a sharp eye for spotting both solid gear and bad gun laws. Whether he’s deep in the woods or deep in editorial deadlines, Larry brings a no-nonsense, tell-it-like-it-is approach to firearms, hunting, and the great American tradition of self-reliance. If there’s a hot debate on gun rights or the latest in hunting tech, you can bet Larry’s got an opinion—and it’s probably backed up with both facts and field experience.
Experience:
– Licensed Bowhunter, Hunter, and Trapper – Experienced in ethical hunting and wildlife conservation.
– Concealed Carry Permit Holder (NYS & AZ) – Trained and licensed to carry in multiple states.
– 2A Journalist – Covering firearms legislation, Second Amendment issues, and gun rights for over a decade.
– Emergency Medical Technician (EMT) – Certified to provide emergency medical care in the field.
– Field-Tested Gear Reviewer – Hands-on experience with firearms, optics, and hunting tech.
I have been thinking that there is some sort of SCOTUS fix in regarding nationwide recognition of carry permits ever since SCOTUS decided Obergefell v. Hodges, 576 U.S. 644 (2015).
For those who need a reminder, that was the Court holding that a marriage license issued in any state to anybody including homosexual couples, had to be recognized and treated as valid by every state in the country. That included states that specifically denied homosexual couples marriage licenses. Think of those denials of marriage licenses to homosexuals as being the same as states that in practice deny carry permits to EVERYBODY except for the special people with special connections to those in power.
As marriage is not even a specifically enumerated right like the Second Amendment which is specific, it follows that if marriage licenses must be accepted and complied with in all states of the country, it logically follows that a license for a specifically named right, i.e. carry permits, should be similarly in the same force as a marriage license nationwide.
Instead we have status where a married homosexual couple’s marriage license must be recognized in a state that didn’t issue it, but if that homosexual couple carries pistols under a carry permit issued by the same state that issued their carry permit into that other state, their marriage is legal and must be respected, but their carry permit is not.
Or if want to put it another way, homosexual marriage is now an unlimited right throughout America, but Second Amendment carry is not. The number of Americans covered by a marriage license issued to homosexuals is just a fraction of the number of Americans in possession of a carry permit to exercise their Second Amendment rights. Therefore, far, far more Americans are affected by this issue than were affected by the question of marriage licenses to homosexual couples.
With that in mind, it is quite correct and rational to be suspicious of why SCOTUS appears to be turning itself inside out to avoid taking up and settling this question.
This is where the speculation begins. Is there a general thread of agreement within SCOTUS, with a general mindset of how they would like to see the question settled so they’re just waiting for the right case to come along favorable for what they want to hand down as the judgement? Or are they hoping President Trump or another Republican will manage to get legislation through forcing all states to recognize carry permits just as those states recognize homosexual carry permits?
Whatever the reason, the SCOTUS tapdancing to avoid taking up one of these cases has become patently obvious.
Pragmatically, how do firearms owners hope to get this resolved with equal justice for them as SCOTUS has provided for homosexual couples? At the moment, the only realistic hope is that Trump and the GOP in the Senate and House put their heads together and pass legislation based on the Obergefell decision in order to make challenges to the legislation deal with making arguments that aren’t clearly contrary to the reasoning behind Obergefell.
The chances of that happening with this current Executive and Legislative branch are about zero, unfortunately.
On a personal level this doesn’t hurt me; I live in Montana and the areas that I choose to travel to in America do not cause me any restrictions or concerns about carrying while in those states. However, unfortunately, the same is not true for many Americans who choose/want to carry.
It sounds to me like a subtle shift in tactics is needed to combat the jurisdictions that are trying to eradicate the second Amendment.
It’s time to bring up Section 1 of the 14th Amendment and point out in a court of law that by putting restrictions on some of the People in some of the States in regards to the 2nd Amendment these jurisdictions are violating the 14th Amendment.
I quote,
“All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside.
No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
The long and the short of my argument is one or a group of State lawmakers cannot take away the Peoples Rights that jurisdiction disagrees with. A persons Constitutional Rights do not diminish or disappear when they cross state lines
Otherwise the 13th Amendment IS POINTLESS and we all know how much wind Democrats now expell on that one.
We and the defense need to think like SCOTUS has to think. Consider this. Is it possible that the Supreme Court had expected it to be brought differently? The way it was appealed may have made a decision not workable in all states. Therefore, SCOTUS could not rule on it without opening a can of worms?
I know they cannot make suggestions for either side in an ongoing trial, it’s more of a take it or leave it type of thing.
Another possibility is there is another case coming up that may give a possibility for a more complete ruling.
I do wish it would have gone through and settled the 2nd Amendment as it was originally intended, but we still wait.
Many on the Supreme Court appear to function just like Republican RINOs! And that dies not include the liberals there!
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SCOTUS Rejects Key CCW Case Gardner v. Maryland
in News
Published On: April 22, 2026 Updated: April 22, 2026 BY Larry Z
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Estimated reading time: 4 minutes
Frustration is boiling over in the Second Amendment community after the U.S. Supreme Court declined to hear Gardner v. Maryland, a case widely viewed as one of the strongest challenges to the patchwork of concealed carry laws across state lines.
According to analysis from William Kirk of Washington Gun Law, the Court’s handling of the case left many wondering whether the justices are willing to step in at all as lower courts and state legislatures continue to test the limits of the Second Amendment.
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And it’s not just the denial. It’s how the Court got there.
Table of contents
A Case That Had Momentum
The “Tease” Before the Denial
Growing Frustration With SCOTUS
Bigger Picture: A Court on the Sidelines?
What This Means Going Forward
Final Thought
A Case That Had Momentum
At the center of the dispute was a Virginia resident, Ava Marie Gardner, a lawful concealed carry permit holder who found herself on the wrong side of Maryland law after a violent road rage incident.
According to Kirk, Gardner was forced off the road and confronted by an aggressive driver. After issuing verbal commands, she displayed her firearm to stop the threat.
Police responded. But the only person arrested was Gardner.
Not for assault. Not for brandishing. But for possessing a firearm in Maryland without the state’s carry credentials, despite being legally permitted to carry in Virginia.
That fact pattern is exactly why many saw this case as the perfect vehicle to address a longstanding constitutional question:
Does the right to carry a firearm stop at a state line?
The “Tease” Before the Denial
What has many in the 2A space especially frustrated is the timeline.
The petition was filed in October 2025. Initially, Maryland waived its response, which often signals a routine denial. But then something unusual happened.
The Supreme Court asked Maryland to respond anyway, triggering a wave of amicus briefs and renewed interest in the case.
Momentum built. Legal support grew. Expectations followed.
Then, after months of delay, including multiple extensions requested by Maryland, the Court reset the case for conference. And just days later, it was over.
Petition denied.
No explanation. No opinion. No guidance.
Growing Frustration With SCOTUS
For Kirk, the takeaway is clear and it’s not comforting.
“Am I going to sit here and tell you there’s some game of 4D chess going on?” he asked. “No, because the evidence just doesn’t suggest that.”
That sentiment is gaining traction.
The Court’s refusal to take up Gardner comes on the heels of other high-profile Second Amendment cases (like Snope v. Brown and Ocean State Tactical v. Rhode Island) where the justices also declined to intervene.
Meanwhile, lower courts continue to uphold restrictions, and states are moving forward with aggressive gun control measures.
Bigger Picture: A Court on the Sidelines?
The denial also lands at a time when new legislation, like the recently introduced Virginia Plan to Reduce Gun Violence Act of 2026, is pushing for sweeping federal restrictions.
At the same time, states like Rhode Island are exploring expanded bans that could include possession of previously legal firearms.
Put it all together, and the concern among gun owners is simple: If the Supreme Court won’t step in now… when will it?
Kirk points to the aftermath of the Court’s 2022 Bruen decision, when many believed stronger Second Amendment protections were on the horizon.
Instead, he argues, the follow-through hasn’t materialized.
What This Means Going Forward
Legally, the denial of Gardner v. Maryland Supreme Court changes nothing overnight.
There’s still no national standard for concealed carry reciprocity. Gun owners remain subject to a complex web of state laws that can turn a lawful act in one state into a criminal offense in another.
But politically and culturally, the impact is harder to ignore. The case had the facts. It had support. It had momentum. And still, the Court passed.
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Final Thought
For many in the 2A community, this wasn’t just another denied petition. It was a missed opportunity. And maybe a warning.
Because if cases like this aren’t enough to get the Supreme Court’s attention, the question becomes unavoidable: Is the Court waiting for the perfect case… or avoiding the issue altogether?
*** Buy and Sell on GunsAmerica! ***
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Larry Z
is a seasoned outdoorsman, lifelong hunter, and the kind of guy who’d rather track whitetails than scroll social media. As an editor for GunsAmerica, he’s got a sharp eye for spotting both solid gear and bad gun laws. Whether he’s deep in the woods or deep in editorial deadlines, Larry brings a no-nonsense, tell-it-like-it-is approach to firearms, hunting, and the great American tradition of self-reliance. If there’s a hot debate on gun rights or the latest in hunting tech, you can bet Larry’s got an opinion—and it’s probably backed up with both facts and field experience.
Experience:
– Licensed Bowhunter, Hunter, and Trapper – Experienced in ethical hunting and wildlife conservation.
– Concealed Carry Permit Holder (NYS & AZ) – Trained and licensed to carry in multiple states.
– 2A Journalist – Covering firearms legislation, Second Amendment issues, and gun rights for over a decade.
– Emergency Medical Technician (EMT) – Certified to provide emergency medical care in the field.
– Field-Tested Gear Reviewer – Hands-on experience with firearms, optics, and hunting tech.
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I am reposting this comment because I believe that he is absolutely correct. Save my name, email, and website in this browser for the next time I comment.
Richard
April 24, 2026, 8:16 am
I believe that SCOTUS is afraid to issue a final, definitive ruling on the Second Amendment and a legal USA law abiding, non-felon, citizens right to carry nationally. Which is, to me, what the Constitution allows. without requiring ANY licensing from any State-Local or Federal agency.
…. If “licensing” can be forced on citizens for the Second Amendment of the U.S. Constitution, .. then why not for our other Constitutional rights.
Why not require licensing for the First Amendment, or the 4th, the 5th, etc. .. Why not give government agencies the power to require citizens to be licensed to use any & all of our Constitutional rights !!! … Yep, SCOTUS is afraid. .. But if you watch The Court. they rarely issue any rulings that are “FINAL” and block government permanently for create laws against citizens rights.
Richard
April 24, 2026, 8:20 am
So where in the U.S. Constitution does it state that government agencies have the power to require licensing to use a Constitutional Right !!!
Please, show us where … we’ll wait while you find it . .. we’re waiting … still waiting .. still waiting … … … …
↩ ∞
I believe that SCOTUS is afraid to issue a final, definitive ruling on the Second Amendment and a legal USA law abiding, non-felon, citizens right to carry nationally. Which is, to me, what the Constitution allows. without requiring ANY licensing from any State-Local or Federal agency.
…. If “licensing” can be forced on citizens for the Second Amendment of the U.S. Constitution, .. then why not for our other Constitutional rights.
Why not require licensing for the First Amendment, or the 4th, the 5th, etc. .. Why not give government agencies the power to require citizens to be licensed to use any & all of our Constitutional rights !!! … Yep, SCOTUS is afraid. .. But if you watch The Court. they rarely issue any rulings that are “FINAL” and block government permanently for create laws against citizens rights.
Sorry but there’s nothing to see here… Move on. She was illegally carrying a firearm in a state that does not recognize her license. This isn’t any different than a doctor or lawyer crossing state line and practicing medicine/law without a license.
I still believe in a state retaining the right to make its own laws in accordance to the will of its constituents.
So where in the U.S. Constitution does it state that government agencies have the power to require licensing to use a Constitutional Right !!!
Please, show us where … we’ll wait while you find it . .. we’re waiting … still waiting .. still waiting … … … …
“The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.” 10th Amendment.
States and their administrations through their agencies can pass any laws or rules they wish under the 10th Amendment. It is then up to the people to challenge those laws and rules in the courts if they deem them to run counter to, or violate the Constitution. No doubt many states violate the Constitution all day long and this is why we have the ability to redress through the court system. SCOTUS is, I believe, waiting for the outcome of HB38, national reciprocity, which allows Congress to address this patchwork problem of gun laws making a much better solution than SCOTUS trying to legislate from the bench.
The 10th Amendment DOES NOT give powers to the States to supersede the Second Amendment . Where’d you go to school ? In order for any government agency two make a law like what you are stating they have the power to do under the 10th Amendment, they would have to override/supersede the Second Amendment . smh … And they DON’T have that power under ANY Constitutional Amendment .
I refer you back to my original statements about requiring licensing for the Second Amendment, then why not all the other Amendments !
Unfortunately, you are right.
If Maryland flat refused to issue carry permits there would be an argument against *Maryland,* but not in this woman’s defense. If upheld, I could fly to New York, and carry in Manhattan on my Colorado permit. A good thing for sure in principle, but SCOTUS was not going to, as one other writer here posited, “legislate from the bench.” SCOTUS won’t infringe on State sovereignty in that manner.
I think we all have a much better chance of seeing SCOTUS at some time in the near future, take on a state AWB and declare such firearms “in common use.” Even Kagan recently said as much in another case.
If you believe as you have stated, then any State can make laws requiring State approval/licensing for any and/or all the other amendments of the U.S. Constitution.
Like I said before … SCOTUS is afraid to make a final judgement against the States requiring Firearm permits .. If they did, it would one less thing the Court would have to cases about … They’re like the departments of government with Welfare … if the problems dealing with welfare were solved, then there would be no need for a government welfare agency .. and if Firearm licensing by the States were ruled Unconstitutional … there would be less SCOTUS cases to deal with.
Yes, i have heard ad infinitum, the “2A is my carry permit!” A lovely pipe dream. I am talking about what *is,* not how you or I would like it to be.
NYC, you re-register your handguns every three years or give them up. Same with the Illinois FOID. Let it expire and your huntin’ rahful is contraband. The Illinois law has withstood legal challenge. Despite Bruen, here in Colorado, I have to renew my carry permit or I don’t get legally to CCW.
If what you believe is true, and believe me I would like it to be, then I eagerly await the SCOTUS ruling that invalidates *all* state and local level firearms permitting and licensing laws. Some of which have been in place for more than a century. In NYC
Are you holding your breath? I’m not…
Again, .. your statements have NOT answered my questions. You give the same liberal pablum as an answer. I suggest you read the records of the Founding Fathers and their reasons as to why the Second Amendment was created .
You are wrong, just as Democrats & liberals are wrong about Court rulings on the 14th Amendment and Birthright Citizenship.
… But I can only lead you to knowledge, I can’t make you think !
“Again, .. your statements have NOT answered my questions. You give the same liberal pablum as an answer.”
Eat your own pablum, Twinks.
And am not your damned research assistant. I described reality that has been accepted by courts for a century. I don’t like it and you don’t have to either. But if you want to test the water, drive into NYC, strap on your repurposed Airsoft chest rig and your $499 M4 clone. and march into Times Square. If you survive, proclaim loudly at your trial that “2A is my carry permit!!!.” Tell it to Melinda Katz, the Queens prosecutor and Alan Bragg, Manhattan DA.
And enjoy your stay at Rikers, like the 65 YO man who recently shot a perp with a pistol for which he did not have a permit, and the AK’s they discovered in his collection which would be perfectly legal where i live but got him put away for four years.
I have popcorn for the show put on by righteous dimwits.
“And enjoy your stay at Rikers, like the 65 YO man who recently shot a perp with a pistol for which he did not have a permit, and the AK’s they discovered in his collection which would be perfectly legal where i live but got him put away for four years.”
I would choose death over that dishonor. That’s also why I’m hoping to get out of the Peoples Republic of Illinois. Indiana seems like a nice choice right now.
Well, I hope you can escape Illinois. I live in Colorado and while it is not as bad as Illinois, the next governor may change that.
There are going to be a lot of victims – martyrs, really – like that old man before this cultural insanity ends.
but states are not allowed to invalidate the constitution and maryland did just that. now food for thought, will this allow any out of state people to be harassed or assaulted by locals……
“Sorry but there’s nothing to see here… Move on. ”
Really? No let’s not – let’s go a little deeper into your objections: So nothing to see here… just like homosexual couples who were married with marriage licenses in one state traveled into another state and attempted to exercise their rights as a married couple in a state that did not recognize marriage licenses issued to homosexuals? And how did the state’s who argued that another state’s marriage license did not apply in their state because they prohibited the issue of marriage licenses to homosexual marriages.
This is where you you get to argue that Obergefell v. Hodges, 576 U.S. 644 (2015), where SCOTUS said if one state issues a marriage license, then all states in the country must recognize that license even if their state refuses to issue marriage licenses for homosexual marriage.
The licensing of professions, by state boards made up of those professions, has no similarity to 2nd Amendment carry – or homosexual marriage licenses.
You are badly confusing the regulations that govern a profession with the civil rights and liberties of the citizens.
“I still believe in a state retaining the right to make its own laws in accordance to the will of its constituents.”
Any particular Amendment in the Bill of Rights you’re confident the constituents of the state can also make laws to deny – other than the Second Amendment and the hidden right to marriage licenses for homosexuals? Maybe a law that prohibits building a mosque or synagogue – authorization something similar to a state Board Of Physicians and Surgeons or State Bar Association?
So don’t just move on, claiming there is nothing to say here: support your position that states can be forced to recognize homosexual marriage licenses by SCOTUS, but they can’t be forced to similarly recognize out of state carry permits… because that’s somehow or other different?
If the USG passed an interstate CCW reciprocity bill, I am betting that SCOTUS would validate it just as they did Obergefell.
But the USG has to pass it. SCOTUS isn’t going to legislate from the bench at that level for CCW.
it’s the job of scotus to support the constitution not show up and get a paycheck! kind of gives me the feeling that this scotus is under control by some group and is doing their wishes.