Whether you can carry a handgun in public depends first on how your state decides who gets a permit. That single question, who holds the power to say yes or no, separates “shall issue” states from “may issue” states, and a 2022 Supreme Court decision reshaped the answer for the whole country. If you carry, teach, or are thinking about getting a permit, it is worth knowing how we got here and where the law stands today.

Shall Issue vs. May Issue

In a shall issue state, the licensing authority must issue a permit if you meet the objective requirements written into the law, such as age, a clean background check, and any required training. The government has no room to say no when you qualify.

In a may issue state, officials had discretion even when you met every written requirement. The applicant usually had to show a special need, often called “good cause,” “proper cause,” or “justifiable need.” A general desire for self-defense typically did not count, so permits were granted sparingly in some places and effectively denied in others.

A third category, constitutional carry (also called permitless carry), lets eligible adults carry without a permit at all. West Virginia, where Tri-State Training is based, is one of those states, though a permit remains useful for reciprocity when traveling.

The Bruen Decision (2022)

On June 23, 2022, the Supreme Court ruled 6 to 3 in New York State Rifle & Pistol Association v. Bruen that New York’s “proper cause” requirement violated the Constitution. Justice Thomas wrote the majority opinion. New York made applicants show “a special need for self-protection distinguishable from that of the general community,” and the Court held that this keeps law-abiding citizens with ordinary self-defense needs from exercising their right to bear arms in public.

The Court described the landscape this way: 43 states were shall issue, and six states plus Washington, D.C. were may issue.

Bruen also replaced the test lower courts had been using. Courts had weighed a gun law’s public-safety benefits against its burden on the right. The Court rejected that as “one step too many.” Now, when the Second Amendment’s plain text covers a person’s conduct, the Constitution presumptively protects it, and the government must show the regulation is “consistent with the Nation’s historical tradition of firearm regulation.”

Where Things Stand Today

Pure may issue discretion is gone. After Bruen, states that had “good cause” or “proper cause” rules dropped or stopped enforcing them. In 2022, for example, Maryland, New Jersey, California, Hawaii, and Massachusetts all stopped requiring applicants to show a special need, though some kept “good moral character” or “suitability” standards. Critics argue those standards still give officials broad discretion, and that is where much of today’s litigation sits.

The fight has moved from who gets a permit to where permit holders may carry. On June 25, 2026, the Court decided Wolford v. Lopez, 6 to 3, with Justice Alito writing for the majority. It struck down Hawaii’s rule banning permit holders from carrying on private property open to the public unless the owner expressly allows it. The Court applied the Bruen test and found Hawaii’s historical examples did not hold up. The decision did not address Hawaii’s separate sensitive-place restrictions or its licensing process.

Wolford matters for Maryland, since the Fourth Circuit in Kipke v. Moore had already held Maryland’s similar private-property default unconstitutional, and that ruling remains in place. Challenges to Maryland’s other location-based carry restrictions are still working their way through the courts.

In West Virginia, permitless carry now applies at age 18 under HB 4106, effective June 12, 2026.

What This Means for You

If you carry, the practical lesson is that the rules change by state and keep changing by court ruling. Permit requirements, training rules, and the places where you may carry can differ sharply once you cross a state line, and recent decisions are still working their way into state law. Check your state’s current statute or your state police or attorney general’s office before you travel or carry somewhere new.

This post is general information, not legal advice.

To talk through permits, training, or safe carry, call 301.988.0809, email tristatetrainer@gmail.com, or visit tristatetraining.org.