Maryland’s Version of ‘Vampire Rule’ Struck Down by Appeals Court

  • 24 Jan 2026
  • Colion Noir

Even as Hawaii’s contentious “vampire rule” is before the U.S. Supreme Court, a lower court last week struck a blow against Maryland’s similar law.

The Fourth Circuit Court of Appeals struck down the state’s private property concealed carry statute on Tuesday, marking a substantial victory for Second Amendment supporters. Maryland, along with Hawaii and a few other outliers, bans carrying weapons on private property without the owner’s express permission.

The three-judge panel declared the prohibition in violation of the Second Amendment.

Maryland’s oppressive law reversed centuries of traditional practices for gun rights

In their unanimous opinion, the judges struck down the ban that had already been set aside in district court. They wrote: “We hold that Maryland’s prohibition on carrying guns on private property held open to the public is unconstitutional and affirm the district court.”

The National Rifle Association (NRA) supported the challenge to Maryland’s law in Kipke v. Moore

The nation’s largest and oldest gun rights organization noted that the victory was decidedly mixed as the Fourth Circuit upheld many other firearm restrictions.

All was not good news from the Fourth Circuit for gun rights

Allowed to stand were prohibitions on possessing weapons “in state parks, state forests, government buildings, museums, public transportation, healthcare facilities, school grounds, stadiums, racetracks, amusement parks, casinos, locations that sell alcohol, and within 1,000 feet of a public demonstration.”

So yes, there remains work to be done.

Maryland was one of several states that responded to 2022’s landmark Bruen decision by adopting every conceivable restriction on carrying firearms outside of the home.

Hawaii was another, and its almost identical law is now before the high court. Oral arguments were presented last week, and several justices appeared skeptical of the Aloha State’s position. 

A ruling is expected by early summer.

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