Maryland Judge Finds Glocks Are Protected Arms, Yet Lets Sales Ban Proceed

Maryland’s SB 334 restricts future transactions in covered Glock and Glock-pattern pistols beginning January 1, 2027. A federal judge denied preliminary relief against the law. IMG Duncan Johnson

Maryland’s Glock sales ban remains on track for January 1, 2027, after a federal judge recognized that the targeted handguns fall within the Second Amendment’s plain text but refused to block the law.

In an October 5 memorandum opinion, U.S. District Judge Richard D. Bennett explained his denial of preliminary injunctions in Bathras v. Moore, consolidated with Duffy v. Moore. Bennett had announced the denial from the bench on September 25.

The result leaves law-abiding Marylanders facing a ban on acquiring covered, factory-built semiautomatic pistols because criminals might illegally convert them into machineguns.

Five days before Bennett issued his written opinion, a Connecticut federal judge blocked a similar restriction. The two courts reached opposing preliminary outcomes on a question that should matter to every gun owner: Can the government prohibit a lawful handgun based on an illegal modification someone else might make?

What Maryland’s Glock Ban Does

SB 334 prohibits manufacturing, selling, offering for sale, purchasing, receiving or transferring a covered “machine gun convertible pistol” beginning January 1, 2027, subject to exceptions.

Its definition targets semiautomatic pistols with a cruciform trigger bar that can be readily converted using a separate pistol converter installed in place of the slide’s backplate. That reaches Glock and Glock-pattern handguns meeting the statutory definition.

Current owners generally may retain their pistols, and the law permits certain immediate-family transfers. But allowing existing owners to keep a gun does nothing for the Maryland resident who wants to buy that same protected handgun after the prohibition begins.

As AmmoLand explained in its coverage of the injunction request, a factory Glock fires one round per trigger pull. A conversion device is a separate component, already subject to federal and Maryland prohibitions, with narrow legal exceptions. The challenged ban reaches the lawful pistol before any conversion occurs.

Protected Handguns, Sweeping Historical Analogies

Bennett recognized that the law targets common handguns before criminal modification and concluded that the challenged conduct falls within the Second Amendment’s plain text. He nevertheless accepted Maryland’s historical defense, relying heavily on the Fourth Circuit’s Bianchi v. Brown decision upholding Maryland’s rifle ban.

The opinion draws connections between SB 334 and restrictions on armed groups, gunpowder storage, Bowie knives, slungshots, blackjacks, short-barreled firearms and machineguns. Bennett treated those laws as evidence of a broader tradition of regulating weapons associated with criminal abuse or extraordinary casualties.

That is an expansive route from regulating dangerous conduct and particular weapons to prohibiting commerce in an ordinary defensive handgun. A gunpowder-storage rule does not, by itself, establish that the government may stop peaceable citizens from buying Glocks.

AmmoLand’s earlier reporting on Maryland’s defense identified the central problem: The state’s theory judges the handgun according to a criminal configuration that does not exist when the lawful buyer purchases it.

Connecticut Judge Refused to Blame Lawful Handguns for Criminal Conversions

In Glock, Inc. v. Griffin and NSSF v. Griffin, U.S. District Judge Kari A. Dooley granted preliminary injunctions on September 30 against Connecticut’s convertible-pistol restriction. Her reasoning exposed the fundamental problem with these bans: A lawful semiautomatic handgun does not lose its constitutional protection because a criminal might later modify it.

Connecticut tried to justify its prohibition by combining Founding-era firearm inspection requirements with restrictions on machineguns. But Dooley identified the gap in that argument. Historical inspection laws ensured that firearms were safely manufactured and operable when sold. They did not establish a tradition of banning safe, functional firearms because someone might subsequently misuse or illegally alter them.

That distinction matters. An unmodified Glock is a semiautomatic handgun. Installing a separate conversion device changes the firearm—and the legal question. Connecticut sought to use restrictions on the resulting machinegun to justify prohibiting the ordinary handgun before any criminal conversion occurred.

The judge emphasized that the targeted, unconverted handguns are safe, extremely popular for self-defense and protected by the Second Amendment. On the record before her, Connecticut had failed to demonstrate a historical tradition sufficient to overcome the presumption that its ban was unconstitutional.

For gun owners, that is the critical difference between the two decisions. Dooley required Connecticut to justify restricting the lawful handgun itself. Bennett accepted Maryland’s broader historical theory that susceptibility to criminal conversion could justify blocking future transactions in that same category of protected arms.

Connecticut’s decision preserves a principle Maryland’s ban undermines: Peaceable Americans should not lose access to constitutionally protected handguns because criminals break laws that already prohibit illegal conversion.

Criminal Misuse Does Not Cancel the Second Amendment

A factory Glock is a semiautomatic handgun. It does not become a machinegun because Maryland politicians give it a new label, and its owner’s rights do not disappear because a criminal might install an illegal device.

Maryland’s approach makes peaceable gun owners pay for crimes they have not committed. Allowing current owners to keep their pistols does not cure that infringement. The right to keep and bear arms cannot survive if the government can prohibit the next buyer from acquiring them.

Bennett recognized that these handguns fall within the Second Amendment’s plain text, then accepted a collection of historical restrictions as justification for cutting off access to them. Gunpowder-storage rules and restrictions on Bowie knives should not become permission slips for banning ordinary defensive handguns.

The stakes extend well beyond Glock. Accept potential criminal modification as grounds for a ban, and anti-gun lawmakers will have another argument to deploy against the next firearm on their list.

“Shall not be infringed” is a command to government. Maryland does not get to turn a criminal’s illegal conduct into a law-abiding American’s lost constitutional right.

Related: Federal Judge Blocks Connecticut’s Glock Ban Before It Takes Effect

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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DOJ Fights Broader NFA Relief After Letting Suppressor Ruling Stand

DOJ is opposing statewide and nationwide NFA relief in the Missouri litigation while gun owners await ATF guidance. Photo: [Tim Potter].

The Justice Department let a major ruling against National Firearms Act registration requirements stand without an appeal. Now it is asking a Missouri federal court to reject relief protecting every resident of the plaintiff states—and gun owners nationwide.

For Americans who own suppressors and short-barreled rifles, the unfinished fight is about who receives enforceable protection from the federal government’s registration scheme.

The October 7 filing comes in the consolidated Brown v. ATF and Missouri ex rel. Hanaway v. ATF litigation before Chief U.S. District Judge Stephen R. Clark.

The NFA’s Taxing-Power Foundation Has Already Failed in Texas

As AmmoLand previously reported, DOJ formally confirmed that it would not appeal the Silencer Shop Foundation ruling.

Judge James Wesley Hendrix held on August 5 that the challenged NFA provisions exceeded Congress’s enumerated powers after Congress reduced the making and transfer taxes on suppressors, short-barreled rifles, short-barreled shotguns, and “any other weapons” to zero.

Washington could no longer justify that regulatory machinery as an exercise of the taxing power. Hendrix also rejected the effort to preserve it under a different congressional power that Congress had not invoked when enacting those provisions.

The Texas opinion did not decide the Second Amendment claims because the enumerated-powers ruling supplied the relief.

Its injunction protects the plaintiffs and, where applicable, their agencies, political subdivisions, members, and customers, including current and future members and customers. It does not automatically protect every American. The Jensen plaintiffs’ relief also excludes AOWs.

DOJ Opposes Relief Covering All State Residents

In its supplemental brief, the DOJ invokes Trump v. CASA to challenge universal relief and argues that states cannot sue the federal government on behalf of their residents under parens patriae standing.

DOJ separately seeks dismissal of Georgia, Kansas, Oklahoma, South Dakota, and Utah on claim-preclusion grounds: they already litigated the same claims to final judgment in Texas.

It also argues that the ten added states supplied no evidence supporting direct governmental injury. Missouri alone attempted to substantiate that theory, DOJ says. The department nevertheless acknowledges that Missouri’s amendment appears procedurally compliant.

These are DOJ’s arguments. Clark has not resolved them in the orders discussed here.

Missouri Challenges Registration and Federal Permission

The amended complaint names Missouri, ten additional states, and individual plaintiff Dave Marshak. It challenges the regulation of untaxed NFA firearms under Congress’s enumerated powers and separately argues that the restrictions on suppressors and short-barreled rifles violate the Second Amendment.

The complaint describes registration, fingerprints, personal information, advance approval, and the threat of criminal prosecution as burdens on lawful ownership. Marshak alleges that he values his privacy and would acquire covered firearms but for the registration requirements.

That is the human consequence behind this procedural fight. Peaceable ownership becomes subject to a federal permission system, with private information surrendered as the price of exercising a right.

The Second Amendment protects the people. Lawful gun owners should not have to enter a federal registry to possess protected arms.

October 22 Conference Will Address What Comes Next

In his October 6 order, Clark noted that the October 5 deadline to appeal the Texas injunction passed without an appeal.

He scheduled a Zoom status conference for October 22 at 10 a.m. CDT, or 11 a.m. Eastern. Counsel must address the Texas judgment’s effect, the five states’ standing, and the validity of Missouri’s amended complaint.

The Texas victory remains consequential. But gun owners outside its protection still need enforceable relief. Constitutional rights belong to every American, and dismantling the NFA’s registration and permission requirements remains unfinished work.

ATF Guidance Could Reshape the Fight Within Days

The next major development could arrive before the October 22 conference. AmmoLand expects ATF’s long-awaited NFA guidance within the next day or two, and its contents could dramatically change the practical impact of this fight for gun owners and dealers.

If ATF adopts an approach extending beyond the people expressly protected by the Texas injunction, that could substantially reduce the immediate uncertainty over how untaxed suppressors and short-barreled firearms are handled. If the agency limits its instructions to covered plaintiffs, members, and customers, the battle for broader court protection becomes even more consequential.

Agency guidance cannot expand a court’s injunction, and it does not carry the same protection as a binding court order. Its release could nevertheless reshape the implementation questions facing both courts and the firearms industry.

The Texas victory is a major step toward dismantling the NFA. ATF’s next move will help determine how far that victory reaches in practice. Gun owners deserve the restoration of their rights, clear instructions, and lasting protection from the federal government’s registration scheme.

Related: DOJ Confirms It Won’t Appeal NFA Ruling on Suppressors and Short-Barreled Guns

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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Everytown’s $10 Million Push Targets Eight House Races and Gun Rights

Michael Bloomberg’s Everytown group isreportedly pumping at least $10 million to help elect eight former Moms Demand Action activists to Congress in November. iStock-915304094

With the midterm elections less than a month away, Everytown for Gun Safety—the billionaire-backed gun prohibition lobbying group founded years ago by former New York Mayor Michael Bloomberg—is reportedly pumping at least $10 million into eight key congressional races in five states in an effort to shift House control to anti-gunners.

Axios and Yahoo News are carrying the report, which identifies the eight candidates so far getting support from Everytown. They are all reported to be “former volunteers for Moms Demand Action,” a subsidiary of Everytown. Reportedly getting Everytown cash are JoAnna Mendoza, running in the 6^th District of Arizona; Pia Dandiya, running in Florida’s 22^nd District; Christina Bohannan (1^st District), Sarah Trone Garriott (3^rd District) and Lindsay James (2^nd District) all of Iowa; Christina Hines (10^th District) and Rep. Kristen McDonald Rivet (8^th District), both of Michigan, and Paige Cognetti (8^th District) of Pennsylvania.

Everytown has also endorsed Democrat Dr. Annie Andrews in her U.S. Senate race in South Carolina against Sen. Darlene Graham, sister to the late Senate powerhouse Lindsey Graham, who died unexpectedly earlier this year. Andrews is a former volunteer at Moms Demand Action and since 2023 has served as a senior advisor for Everytown. Andrews’ position on guns can be found here.

There is no small irony in this, considering how The Trace, another Bloomberg-backed entity which supports gun control efforts under the guise of news, once lamented about all the money the National Rifle Association spent to support pro-rights candidates.

Not reported, except perhaps by TheGunMag.com and Ammoland News, were the contributions Bloomberg and other wealthy anti-gunners have made over the years to support gun control, including restrictive anti-Second Amendment initiatives in Washington state. Presumably pouring millions of dollars into the campaign war chests of gun grabbing Democrats is okay, while supporting candidates who defend the Second Amendment is not.

A story at Axios quotes John Feinblatt, president of Everytown, stating, “For nearly two years, a MAGA House has rubber-stamped the Trump administration as it tore up federal gun safety laws, and flipping these eight seats is how we put a stop to it…There’s a Moms Demand Action volunteer on the ballot in every one of these districts, and we’re partnering with House Majority PAC to turn them into majority makers.”

Feinblatt overlooks multiple U.S. Supreme Court rulings which have overturned key elements of the gun control agenda, and appear poised to do it again by accepting for review a pair of cases challenging bans on so-called “assault weapons,” Viramontes v. Cook County (Illinois) and Grant v. Higgins (Connecticut), both involving the Second Amendment Foundation (SAF). Oral arguments are scheduled for Wednesday, Dec. 2, and an opinion is expected sometime in June 2027.

In 2008, the gun ban in Washington, D.C. was overturned and two years later, the decades-old handgun ban in Chicago was nullified as the high court incorporated the Second Amendment to the states via the 14^th Amendment in the SAF-led case of McDonald v. City of Chicago. That opened the floodgates, allowing challenges of state and local gun control laws and regulations on Second Amendment grounds. The 2022 Bruen ruling struck down New York’s arbitrary and restrictive gun permit law, which unconstitutionally prevented untold millions of Empire State citizens from exercising their right to keep and bear arms for an entire century.

In response to the big money support for the eight (so far) female Democrats running for Congress, National Republican Congressional Committee spokesman Mike Marinella told Axios, “House Democrats have fully embraced the radical socialist agenda of abolishing prisons, releasing criminals back on the streets, and defunding the police.”

Democrats and their gun control allies have been furious lately over moves by the Bureau of Alcohol, Tobacco, Firearms and Explosives to change their enforcement approach dramatically under Director Robert Cekada, who made history by appearing recently at the Gun Rights Policy Conference in Dallas, Texas. He assured the conference audience of Second Amendment activists that ATF is backing away from Biden-era policies which were aimed at putting many federal firearms license holders out of business.

As the Nov. 3 elections draw closer, many races are tightening, and there are efforts around the country, especially on social media, to turn out the conservative/gun owner voters, who all-too-often in the past have demonstrated lethargy, if not downright apathy, toward voting in midterm elections.

Related: Denver Carry Ban Becomes Latest Fight for Nationwide Gun Rights

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About Dave Workman

Dave Workman is a senior editor at TheGunMag.com and Liberty Park Press, author of multiple books on the Right to Keep & Bear Arms, and formerly an NRA-certified firearms instructor.

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Gun Trace Data Turns Lawful Dealers Into Gun-Control Targets

Firearm transaction records cannot, by themselves, establish wrongdoing by an FFL. AI-generated editorial illustration for AmmoLand.

Selling firearms to Americans exercising their Second Amendment rights is not evidence of wrongdoing. Neither is discovering, years later, that police recovered a gun a retailer once handled.

That distinction is at the center of “The Limits of Crime-Gun Trace Data,” a rebuttal published by the University of Wyoming’s Firearms Research Center (FRC). Attorneys Jason A. Davis, C.D. Michel, and Anna M. Barvir challenge The Trace’s effort to use California firearm-recovery statistics to cast suspicion on Turner’s Outdoorsman.

The authors explain how narrow statistics, expansive definitions, and inconsistent comparisons produce a much more accusatory story than the evidence supports. For gun owners, the stakes extend beyond one retailer: records of lawful commerce are being used to put the businesses serving them under suspicion.

A Sweeping Accusation Built on a Restricted Sample

The Trace’s May coverage claims Turner’s accounts for roughly a fifth of California’s firearm sales and a quarter of its “crime guns.”

The methodology describes something considerably narrower. That quarter concerns firearms both sold and recovered during 2022–2024 within the available dealer dataset. Dealers with no associated crime-gun recovery were excluded from the sales figures.

It does not mean Turners supplied a quarter of all crime guns recovered across California.

The reporting also cites 7,922 firearms associated with Turner’s during that recovery window. That raw count includes guns sold before 2022. It measures something different from the restricted sales-and-recovery comparison.

Using those figures together invites readers to attach a sweeping accusation to a limited calculation. Neither number establishes that a dealer knowingly participated in an unlawful transaction.

California’s Own Records Undercut the Narrative

California DOJ’s July 2026 report warns that a firearm’s later recovery as a crime gun: “does not necessarily indicate negligence or wrongdoing by the dealer.”

“Additionally, the fact that a dealer sold or transferred a firearm later recovered as a “crime gun” does not necessarily indicate negligence or wrongdoing by the dealer. For example, if a rigorously compliant firearm dealer sold or facilitated the delivery of a firearm to an eligible person who later modified it into an illegal weapon; or a firearm was seized by law enforcement from an eligible person who became legally prohibited from keeping it; or a firearm was associated with suicide or attempted suicides; or a firearm is found or recovered by a law enforcement agency without the agency specifically knowing whether the firearm was used in a crime, that firearm may be traced as a crime gun to that dealer.”

Source: Crime Guns, Inspections, and Handguns in California, California Department of Justice

DOJ describes circumstances involving fully compliant dealers: an eligible purchaser later becomes prohibited, a firearm is subsequently modified into an illegal configuration, or police recover a found firearm without knowing whether it was used in a crime. Suicide-related recoveries can also enter the dataset.

That is a much broader category than guns used to rob, assault, or murder someone.

During 2023–2025, DOJ could associate only 38,592 of 140,883 unique serialized crime guns, 27.4%, with specific California dealers. Missing matches can reflect older lawful transactions, incomplete records, or inconsistent entries.

The matched “source” can also be a dealer-facilitated private transfer, pawn redemption, or return of a temporarily stored firearm. Appearing in the records does not automatically mean the dealer originally supplied the gun from its inventory.

A government classification cannot make a lawful sale culpable after the fact.

A Large Retailer Is an Easy Statistical Target

The FRC rebuttal challenges comparisons that combine Turner’s many locations without consistently combining competing chains. It also identifies sales volume, geography, product mix, prices, and clientele as factors requiring consideration.

A chain serving densely populated communities and selling affordable handguns will have a different recovery profile from a small shop specializing in expensive hunting firearms.

A meaningful analysis must account for those differences. Ranking businesses by recovery totals and attaching suspicion to the largest sellers skips that work.

Affordable firearms matter to Americans who cannot spend thousands of dollars on a defensive handgun. Their right to keep and bear arms is no less protected than anyone else’s. Serving them should not become a liability.

Recovery Records Cannot Tell a Dealer’s Future

The rebuttal distinguishes what a retailer can know during a sale from what investigators learn afterward. Later recovery does not establish that the seller ignored an apparent straw purchase or knew the purchaser was prohibited.

The May coverage itself contains descriptions of careful Turner’s practices, including employee accounts of tight sales procedures, an ATF inspection’s description of meticulous recordkeeping, and the company’s refusal to complete transactions with undetermined background-check results. www.thetrace.org

Those practices are relevant to accusations about how the company operates. So is the absence of evidence connecting particular recovery counts to particular unlawful sales.

The August coverage reports a possible straw-purchase violation identified during a 2025 inspection of the San Bernardino store, alongside 781 associated firearm recoveries during 2023–2025. A possible violation does not establish that hundreds of other transactions were unlawful or that the store engaged in systemic trafficking.

Gun Owners Have Heard the Tracing Sales Pitch Before

ATF’s disclaimer warns that traced firearms are not a representative sample of all firearms used by criminals. Their recorded retail sources do not necessarily establish how criminals acquired them.

AmmoLand has repeatedly examined tracing’s failures. In “Old Dominion Terror Attack Exposes the Myth of Gun Tracing,” Dean Weingarten reported that investigators identified the alleged supplier through telephone records, rather than through tracing the stolen firearm.

AmmoLand has also challenged the accumulation of firearm transaction records under the tracing justification.

The FRC article exposes another use for those records: guilt by association against lawful dealers.

The Second Amendment recognizes a preexisting right. It does not make gun ownership conditional on a retailer predicting every purchaser’s future, nor does it authorize punishing lawful commerce because someone later misuses a firearm.

Responsibility belongs to the person who commits the crime. Selling Americans the means to defend themselves is not a crime—and statistical insinuation cannot make it one.

Related: ATF’s Hidden Gun Registry: How a ‘Tracing System’ Became a Billion-Record Database

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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Everytown Bankrolling Democrats in Midterms Could See Virginia Results Repeated Nationwide

Everytown for Gun Safety is committing $10 million to help elect Democratic congressional candidates with ties to Moms Demand Action ahead of the 2026 midterms. IMG Jim Grant

“Scoop: Gun control group gives Dems a $10 million midterm assist,” Axios reported Tuesday. “Everytown for Gun Safety, a group that advocates for stricter gun laws, is teaming up with House Democrats on a $10 million ad campaign to boost former gun safety advocates now running for Congress.”

“The candidates boosted by the campaign are all former volunteers for Moms Demand Action,” the report elaborates, identifying them as:

JoAnna Mendoza of Arizona, Pia Dandiya of Florida, Christina Bohannan, Sarah Trone Garriott and Lindsay James of Iowa, Christina Hines and Rep. Kristen McDonald Rivet of Michigan, and Paige Cognetti of Pennsylvania.

That they’re all Moms Demand endorsees certainly should tell right to keep and bear arms advocates everything they need to know. What’s interesting, though, is all the other issues Everytown, seeded by billionaire (and presumptive Republican) Michael Bloomberg are willing to enable, all in the name of gutting the Second Amendment.

So, they’re evidently unconcerned about the radical lurch leftward the Democrat Party is taking while its old guard is being challenged – and in some cases replaced  – by overt socialists bent on imposing radical changes on more than guns. And there’s more: In case after case, the prohibitionists have backed “candidates of distinction” who certainly are distinct from the mainstream  – but as long as they’re against guns, they get the nod.

For all the noise about Republicans being the “party of the rich” and Democrats being the “party of the workin’ man,” you wouldn’t know it from the top 10 midterm money-raisers, nine of whom are Democrats, and all of whom have gun-grabber blessings.  Indeed, another Everytown-endorsed “gun sense candidate,” Abdul El-Sayed, who rails against money in politics is the beneficiary of  “[t]he Soros family’s political machine [which] has dumped millions into political committees that are supporting El-Sayed’s run for Senate,” and of a “$30 million pledged by the Senate Majority PAC.”

The fast-approaching midterms are going to set the tone for pending attacks against the Second Amendment that Democrats dare to launch, all with the goal of establishing the momentum to take the White House, the House of Representatives, and the Senate in 2028.

If they succeed, look for all the many advances made to date to restore the right to arms to be reversed, including the ATF/Department of Justice rules and positions changing, all of which can be changed back by a Democrat administration on Day One that President Harris or whomever takes office.

Even if the Supreme Court hands gun owners a win soon against “assault weapon” bans, Samuel Alito is broaching the subject of retirement, Clarence Thomas isn’t getting any younger, and Democrats are dead serious when they talk about “packing the court” once they have the power to make it happen.

And past rulings have been overturned before.

Will the Republicans blow their majorities? They certainly are adept at disappointing supporters and taking the fire out of constituent bellies. No one points this out more than gun owners who are sick and tired of “lesser of two evils” choices and legislative gutlessness.

That said, we complain a lot, but be honest—how many of us do more than that (donate, work campaigns, spread the word… vote)?

But – and there’s a word that should get everyone’s suspicions up – like it or not, two parties dominate and the election will be binary. That’s just the way it is, and no amount of arguing is going to change that. If efforts weren’t made to oust the poltroons in the primaries, the choice will be them or the out-and-out gun-grabber (unless the Republican is an out-and out-gun-grabber like Pennsylvania’s Brian Fitzpatrick).

There is a third choice bandied about by some, TINVOWOOT (There is No Voting Our Way Out of This), which will guarantee the Democrats win. Those of us who can see advancements made in “gun rights” over the last few years have reason to believe the remarkable system bequeathed to us by the Framers of the Constitution yet provides a means of redress that will take a lot less personal effort and sacrifice.

We saw what happened in Virginia when too little money was raised and too many gun owners sat on their hands. If that happens nationally, those who won’t lift a finger on a minimal citizenship effort had best be prepared for what will come.

Wouldn’t it be easier just to vote?

Related: CDC Corrects Defensive Gun Use Estimates After Gun-Control Push to Bury Them

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About David Codrea:

David Codrea is the winner of multiple journalist awards for investigating/defending the RKBA and a long-time gun owner rights advocate who defiantly challenges the folly of citizen disarmament. He blogs at “The War on Guns: Notes from the Resistance,” is a regularly featured contributor to Firearms News, and posts on Twitter: @dcodrea and Facebook.

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Denver Carry Ban Becomes Latest Fight for Nationwide Gun Rights

Four carry permits still leave Gene Hoffman unable to carry publicly for self-defense in Denver. FPC’s lawsuit challenges the restrictions. Composite illustration by AmmoLand News using a firearm photo by Duncan Johnson and an AI-generated background.

Gene Hoffman holds concealed-carry permits from California, Utah, Arizona, and Florida, but none allows him to carry a handgun publicly for self-defense when he visits Denver. According to a federal lawsuit brought by Hoffman and Firearms Policy Coalition, Colorado’s residency and reciprocity restrictions combine with Denver’s open-carry ban to leave him without a lawful avenue to exercise that right, even though he is willing and otherwise able to meet Colorado’s permit requirements.

FPC and Hoffman filed Hoffman v. City and County of Denver on September 29 in the U.S. District Court for the District of Colorado. Their October 6 amended complaint challenges the denial of public carry to otherwise-qualified visitors and seeks access to Colorado carry licenses for Hoffman and similarly situated individuals, including FPC members. The case confronts a problem familiar to traveling gun owners: a collection of permits can still leave an American disarmed at his destination.

How Colorado and Denver Close Both Avenues for Carry

Hoffman is a California resident who travels to Denver at least two or three times annually to visit friends and his son, who attends Colorado State University. The complaint says he plans to return in January 2027 and would carry a handgun for lawful self-defense if the challenged restrictions did not prevent him from doing so. It also alleges that he could satisfy Colorado’s permit criteria apart from its residency requirement.

Colorado generally reserves its concealed-handgun permits for residents and recognizes qualifying out-of-state permits only when the holder resides in the issuing state. Because Hoffman lives in California, which lacks reciprocity with Colorado, his California permit is not recognized, and his nonresident permits from Utah, Arizona, and Florida do not overcome the restriction. Although Colorado generally permits open carry, Denver prohibits it, closing the other avenue for carrying a handgun publicly.

The complaint identifies 15 states and Washington, D.C., without Colorado reciprocity, placing their otherwise-qualified residents in the same position when seeking to carry publicly in Denver. For those visitors, the restrictions do more than dictate whether a handgun must be carried openly or concealed; the plaintiffs argue that they eliminate both options and deny the public-carry right recognized in New York State Rifle & Pistol Association v. Bruen.

American History Protected Armed Travelers

The lawsuit’s Second Amendment claim draws on Bruen’s requirement that the government justify a challenged restriction through the nation’s historical tradition of firearm regulation once the amendment’s text covers the conduct. FPC argues that carrying a handgun publicly for self-defense plainly falls within that protection and that American history provides no justification for stripping otherwise-qualified citizens of the right because they live in another state.

“Even when states did not require that travelers carry arms, there is a longstanding historical tradition—stretching from before the Founding until after Reconstruction—of traveler exceptions to carry restrictions that otherwise applied,” the complaint states.

It cites a 1686 New Jersey law restricting the carrying of certain weapons while exempting “all strangers, travelling upon their lawful occasions thro this Province, behaving themselves peaceably.” It also identifies traveler exceptions in Kentucky, Tennessee, Arkansas, and Alabama, among other jurisdictions.

The complaint further cites colonial laws requiring travelers to carry arms for their safety. These examples support the plaintiffs’ argument that travelers were historically afforded greater freedom to be armed because of the dangers they faced away from home. Colorado and Denver impose the opposite treatment on people in Hoffman’s position, excluding them from lawful public carry because of where they reside.

A Separate Challenge to Residency Discrimination

The lawsuit also invokes Article IV’s Privileges and Immunities Clause, which protects citizens against certain forms of discrimination when they enter another state. The complaint cites Supreme Court precedent explaining that the clause bars discrimination against out-of-state citizens when there is no substantial reason beyond their residency. Hoffman alleges that Colorado excludes him from its permitting process despite his willingness and ability to satisfy the other requirements, while qualified Colorado residents can obtain permits.

That exclusion has consequences beyond Denver’s open-carry ban. The complaint points to permit-dependent protections involving handgun possession in vehicles on public-university campuses and carry in parking areas adjacent to certain government buildings. Hoffman says he would also possess a handgun in his vehicle in Colorado State University’s parking area if he could obtain a valid permit, connecting the licensing challenge directly to his trips to visit his son.

The federal Gun-Free School Zones Act creates an additional obstacle. As FPC explains, its qualifying-license exception requires a license issued by the state where the school zone is located or one of that state’s political subdivisions. Recognition through reciprocity does not itself satisfy that exception. The amended complaint therefore asks for Colorado licenses as necessary for complete relief, along with declaratory relief, preliminary and permanent injunctions, nominal damages against Denver, and attorney’s fees.

Building the Case for Nationwide Carry Rights

Constitutional attorney Mark Smith, host of The Four Boxes Diner, argues that Colorado and Denver’s overlapping restrictions amount to an effectively full-blown carry ban for Hoffman.

Denver prohibits him from carrying openly, while Colorado’s permit rules prevent him from carrying concealed, leaving neither avenue available for public armed self-defense. Smith explains that this complete denial violates Bruen’s recognition that the Second Amendment protects the right to carry a handgun publicly for self-defense. To justify that prohibition, the government must identify a supporting historical tradition, yet the complaint documents laws that protected armed travelers and sometimes afforded them greater carry freedom than residents. Smith views the case as another step toward establishing that Americans retain their right to bear arms when they cross state lines.

In Bruen, after examining the text of the Second Amendment and the Nation’s historical tradition of firearm regulation, the Supreme Court held that “the Second and Fourteenth Amendments protect an individual’s right to carry a handgun for self-defense outside the home.”

The Supreme Court did not qualify that holding by recognizing only a right to carry in one’s state of residence, and there is no historical tradition of states or localities imposing such restrictions. Indeed, far from supporting such a restraint on bearing arms, and although it is not Plaintiffs’ burden to carry, the Nation’s historical tradition squarely rejects it.

Source: Complaint in Hoffman and Firearms Policy Coalition v. Denver, U.S. District Court, District of Colorado

FPC has already made progress against residency restrictions in California, New York, and Louisiana, and Denver is the next fight in that broader effort. For gun owners, these cases address a familiar problem: planning a trip means sorting through conflicting carry laws, collecting additional permits, and still being told to leave their defensive handgun behind. Hoffman’s four permits show how far that system remains from respecting the right to bear arms.

“Colorado and Denver cannot deny millions of Americans their right to carry. As we’ve successfully shown in other cases, fundamental rights do not stop at state lines. The Second Amendment protects the People, period—not just where they live. We have already litigated to eliminate residency-based carry barriers in California, New York, and Louisiana, and we are going to keep pressing this issue throughout the United States,” said FPC President Brandon Combs.

Americans traveling to visit family, work, or take a vacation have the same right to protect themselves that they have at home. The Denver lawsuit seeks to restore that freedom for Hoffman and others in his position, moving the country closer to honoring the right wherever Americans travel.

Restoring the Second Amendment means ending the treatment of armed self-defense as a privilege that expires at a state line.

Related: Oklahoma Guardsman Faces D.C. Gun Felony as Congress Stalls on Carry Reciprocity

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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CDC Corrects Defensive Gun Use Estimates After Gun-Control Push to Bury Them

The CDC now cites estimates of 500,000 to 2.5 million defensive gun uses annually. AmmoLand graphic created with AI assistance using a handgun photograph by Duncan Johnson; research wording sourced from the CDC.

The Centers for Disease Control and Prevention now cites estimates of 500,000 to 2.5 million defensive gun uses each year, correcting its public discussion of armed self-defense after gun-control activists successfully pushed the agency to remove the figures in 2022.

The correction replaces the previously published lower estimate of 60,000. It follows the restoration of the defensive gun use estimates earlier this year, which AmmoLand covered in August.

For gun owners, the history behind that change matters. One of the people who wanted the numbers removed was Gun Violence Archive executive director Mark Bryant, who complained that gun-rights advocates used the research to stop gun-control legislation from passing.

What the CDC Changed

The CDC’s firearm injury and death webpage attributes its current range to the 2013 National Academies report, Priorities for Research to Reduce the Threat of Firearm-Related Violence. A footnote acknowledges that the page was updated to reflect the report’s discussion of defensive gun use.

These are estimates from existing research, rather than findings from a new CDC survey. The agency explains that results differ depending on survey questions, populations, timeframes, and study design.

In an October 5 article, the Crime Prevention Research Center welcomed the correction. CPRC argues that the earlier lower figure inadequately reflected problems with National Crime Victimization Survey estimates.

The CDC Corrects its Post on Defensive Gun Uses

The Trump administration restored the post as it originally appeared before the CDC removed it and has now corrected an error in the original version.

https://t.co/AhFvHNuxJZ
#2a #guns #dgu #guncontrol

— John R Lott Jr. (@JohnRLottJr) October 5, 2026

The National Academies report, on pages 15–16, recognizes armed self-defense as common, citing national survey estimates ranging from roughly 500,000 to more than 3 million defensive gun uses annually. That is substantial evidence of Americans using firearms to protect themselves against criminals.

The report also flags a critical weakness in the much lower NCVS-based estimate of 108,000 annual defensive uses: respondents were not specifically asked about defensive gun use, making that figure difficult to interpret.

Gun-control advocates cannot honestly treat a survey that never specifically asked about armed self-defense as the final word on how often it occurs. The report’s warning belongs alongside that lower estimate whenever it is cited.

GVA Wanted the Numbers Gone

The political pressure is documented in emails reported by The Reload in December 2022.

Bryant joined GVPedia’s Devin Hughes and Newtown Action Alliance’s Po Murray in a September 2021 meeting with CDC officials. Their campaign targeted the agency’s presentation of defensive gun use research, particularly the high-end estimate associated with criminologist Gary Kleck.

Bryant requested removal of an estimate that “has been used so often to stop legislation.” He also complained that the research had stalled gun-control policy.

The CDC subsequently removed the numerical range and research link in 2022. GVA participated in the lobbying campaign; federal officials made the decision.

The emails also show that CDC officials initially defended the webpage’s wording. They recognized that GVA’s documented incidents represented only a limited portion of defensive gun uses, including because some incidents never reach official sources.

AmmoLand Has Already Exposed GVA’s Anti-Gun Agenda

Lee William’s 2021 investigation of the Gun Violence Archive examined its expansive mass-shooting definition, reliance on media and law-enforcement reports, and Bryant’s public support for gun restrictions.

GVA’s definition counts incidents involving four or more victims shot, including wounded survivors, and can include gang, drug, and domestic violence. That produces a category broader than the indiscriminate public attacks many readers picture when they hear “mass shooting.”

Bryant also endorsed restrictions on standard-capacity magazines, dismissing 30-round magazines and 60-round drums as hobby equipment outside the Second Amendment.

William’s June 2024 follow-up challenged the media’s use of GVA figures for sensational headlines and documented a lawmaker using one such story to promote an “assault weapon” ban.

That record gives gun owners ample reason to reject the pretense that Bryant’s intervention at the CDC was detached from gun-control politics.

Armed Self-Defense Belongs in the Public Record

The CDC’s correction does not establish an exact annual count or mean every defensive gun use saved a life. It does restore a fuller account of research on Americans using firearms for protection.

Government agencies should not bury that evidence because it makes gun bans harder to sell.

The Second Amendment protects the right to keep and bear arms. That right does not depend on Gun Violence Archive’s bogus research or whether armed self-defense complicates the next gun-control campaign.

Shall not be infringed has no statistical threshold.

Related: Armed Citizen Used a Suppressed Pistol to Save Lives at Twin Falls In-N-Out

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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