A three-judge panel for the United States Court of Appeals for the Fourth Circuit struck down Maryland’s private property concealed carry ban on Tuesday.
The case centered on the ban reached the Fourth Circuit on appeal after being heard in May 2025 in the United States District Court for the District of Maryland.
The three judges hearing the case were: Chief Judge Albert Diaz, Circuit Judges Roger L. Gregory, and G. Steven Agee.
The judges weighed Maryland’s private property concealed carry ban via the methodology set forth in Bruen (2022). Then, “Judge Gregory, joined by Chief Judge Diaz, [wrote] for the Court, and Judge Agree joins,” saying, “We hold that Maryland’s prohibition on carrying guns on private property held open to the public is unconstitutional and affirm the district court.”
A similar ban, commonly referred to as a “Vampire Rule,” is also in place in Hawaii and is being challenged in the U.S. Supreme Court.
AWR Hawkins is an award-winning Second Amendment columnist for Breitbart News and the writer/curator of Down Range with AWR Hawkins, a weekly newsletter focused on all things Second Amendment, also for Breitbart News. He is the political analyst for Armed American Radio and the director of global marketing for Lone Star Hunts. He holds a PhD in Military History with a focus on the Vietnam War (brown water navy), U.S. Navy since Inception, the Civil War, and Early Modern Europe. Follow him on X: @awrhawkins. You can sign up to get Down Range at breitbart.com/downrange. Reach him directly at awrhawkins@breitbart.com.
