History of concealed carry in the United States

The Court did not invalidate any of the other provisions of New York's law requiring people who carry guns in public to obtain a permit.

A meta-analysis conducted by the RAND Corporation of over 30 studies up to 2019 concluded, "the best available studies provide inconclusive evidence for the effect of shall-issue laws" on total homicides, firearm homicides, robberies, assaults, and rapes, and that "there is limited evidence that shall-issue laws may increase violent crime".

[4] A study of states that adopted permitless concealed carry laws found that such states experienced a 13% increase in fatal and nonfatal police shootings of civilians compared to what would have been expected had stronger carrying standards remained in place.

However, the constitutions of 32 states expressly protect an individual right to keep and bear arms (Alabama, Alaska, Arizona, Colorado, Connecticut, Delaware, Florida, Illinois, Indiana, Kentucky, Louisiana, Maine, Michigan, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Dakota, Oklahoma, Oregon, Pennsylvania, South Dakota, Texas, Utah, Vermont, Virginia,[7] Washington, West Virginia, and Wyoming).

Case law in 9 other states (Arkansas, Georgia, Idaho, North Carolina, Ohio, Rhode Island, South Carolina, Tennessee, and Wisconsin) protects the individual right, making a total of 41 states that expressly protect an individual right to keep and bear arms.

This could theoretically also cause problems under the Gun-Free School Zones Act of 1990, which through its 1000-foot radius provision, makes unlicensed carrying of firearms illegal under Federal law in nearly every part of any city or town, although in practice this Act is rarely (if ever) enforced against persons who are not either on school property or committing some other crime.

For these reasons, every other state to adopt constitutional carry has kept its previously existing permitting process in place.

Rivers H. Buford, associate justice of the Florida Supreme Court, said that the Florida law banning concealed carry, "[t]he original Act of 1893 ... was passed for the purpose of disarming the negro laborers ... and to give the white citizens in sparsely settled areas a better feeling of security.

... [I]t is a safe guess to assume that more than 80% of the white men living in the rural sections of Florida have violated this statute.

It is also a safe guess to say that not more than 5% of the men in Florida who own pistols and repeating rifles have ever applied to the Board of County Commissioners for a permit to have the same in their possession and there has never been, within my knowledge, any effort to enforce the provisions of this statute as to white people, because it has been generally conceded to be in contravention to the Constitution and non-enforceable if contested.

The State of New York passed the Sullivan Act in 1911 that required a license to possess a concealed firearm.

The Georgia Legislature passed a bill introduced by Lieutenant Governor Zell Miller, which became the model for later laws.

The heart of the law was that the job of administering the shall-issue permit process was given to a non-law enforcement, elected official, the Probate Court Judge.

In 2008, the Supreme Court of the United States decided District of Columbia v. Heller, the first time it had struck down a gun law on Second Amendment grounds.

In 2010, Arizona became the third state after Alaska and Vermont (and the first with a significant urban population) to allow constitutional carry.

2013 also marked the last of the 50 states to abandon a no-issue policy when Illinois, after the 2012 Moore_v._Madigan case challenging the total ban of concealed carry within the state was decided in favor of the plaintiffs, adopted a shall-issue licensing policy within the timeline established by the Court.

In 2022, three states adopted constitutional carry: Ohio, Georgia, and Indiana; Alabama enacted legislation to allow it beginning January 1, 2023.

However, there remain inconsistencies in how much certain state and local governments are complying with the Supreme Court ruling and whether ordinary citizens can de facto obtain permits in previously may-issue jurisdictions.