Valid D.C. Permit, Two Maryland Convictions Anyway: Eight 2A Groups Urging Maryland’s Highest Court to Hear Duvall Carry Case

Estimated reading time: 5 minutes

ANNAPOLIS, MD — Eight Second Amendment organizations, the Second Amendment Foundation, Maryland Shall Issue, the National Rifle Association, the California Rifle & Pistol Association, the Minnesota Gun Owners Caucus, the Second Amendment Law Center, the Citizens Committee for the Right to Keep and Bear Arms, and the Cato Institute, filed an amicus brief on July 23, 2026, urging the Supreme Court of Maryland to take up Darius Duvall v. State of Maryland. The question underneath it is simple to state: can Maryland arrest and convict a man for carrying a handgun when he holds a valid District of Columbia carry permit?

The facts come from the Appellate Court of Maryland’s opinion. On November 21, 2021, Duvall was a passenger in a vehicle pulled over for speeding in Prince George’s County. The officer smelled burnt cannabis and a faint odor of alcohol, and after backup arrived, Duvall and the driver were asked to step out. A search of the vehicle turned up a loaded handgun in the pocket of a jacket in the rear seat. Duvall told the officer he had a permit for it. He did. She found the carry permit, issued by Washington, D.C., in his wallet. Because it was not a Maryland permit, she arrested him.

Sit with that sequence. He disclosed the gun. He produced a government-issued license proving he had been vetted and cleared to carry it. And the encounter still ended in handcuffs, because the license came from the wrong side of a state line. A Prince George’s County jury went on to convict him of wearing, carrying, or transporting a handgun in a vehicle and of carrying a loaded handgun, both under § 4-203 of Maryland’s Criminal Law Article. He had moved before trial to quash the arrest and suppress the evidence, arguing the arrest violated the Second Amendment. The trial court denied the motion, and on May 21, 2026, the Appellate Court of Maryland affirmed in an unreported opinion. His petition for certiorari now sits with the Supreme Court of Maryland, the state’s highest court.

Here is the permit-recognition piece in plain terms. In the states, recognition happens two ways. Some states sign formal reciprocity agreements with each other. Others honor out-of-state permits on their own, with no agreement in place at all. My concealed carry reciprocity maps show which states do which. Maryland does neither. It recognizes no other jurisdiction’s carry permit, so a D.C. license, however valid, counts for nothing once you cross into the state.

The groups’ argument is that this is nothing new, and that history already settled it in the traveler’s favor. For most of American history, when states and cities restricted carrying firearms, they wrote in exceptions for people traveling from out of state. According to SAF’s announcement of the filing, that traveler’s exception shows up in colonial-era laws, in early nineteenth-century statutes from Kentucky, Indiana, Tennessee, Arkansas, and Alabama, and after the Civil War in states including Nevada and California, with more than 80 historical examples compiled. Maryland, by contrast, has no traveler exception at all, and the brief says that puts the state outside the historical tradition.

“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.”

To be clear about where this stands: Duvall was convicted, the conviction was affirmed, and the Supreme Court of Maryland has not decided whether it will hear the case. A petition for certiorari is a request, not a right. The appellate opinion is unreported, which means it cannot even be cited as precedent in Maryland’s own courts.

More from USA Carry:

Part of a serious carry mindset is knowing the law of every state you enter, because right now the map, not your permit, decides whether you are a licensed citizen or a criminal case number. This petition asks whether that map has to answer to history. The amici say more than 80 old statutes already answered it.

I will continue tracking Duvall v. State of Maryland as the Supreme Court of Maryland decides whether to grant review.