By Harold Hutchison
Multiple pro-Second Amendment groups filed an amicus brief urging the Maryland Supreme Court to hear an appeal of a case involving a D.C. resident arrested for carrying a firearm in Maryland.
“In 2022, Lloyd Muldrow, a Marine veteran and self-defense instructor, stopped an attack by an armed assailant in a Baltimore bar. For his heroism, he would later receive the Carnegie Medal, which recognizes those who perform extraordinary acts of heroism in civilian life. But before that recognition, he suffered the humiliation of arrest and prosecution solely because he carried a firearm in Maryland with a Virginia carry permit, which Maryland refused to honor. As reported, ‘police thanked him—and then they arrested him.’ Mr. Muldrow would eventually receive probation for his “crime.” His experience underscores that the issue of interstate carry rights is not limited to this case. Rather, it threatens responsible, licensed carriers nationwide,” noted the gun-rights groups and the Cato Institute in their amicus brief.
Maryland’s gun laws are some of the most stringent in the country. These laws include a blanket refusal to recognize out-of-state permits or to make reciprocity agreements with other states, according to the Maryland State Police.
Gun-rights groups such as the Second Amendment Foundation (SAF) and the Citizens Committee for the Right to Keep and Bear Arms (CCRKBA) urged the state court to hear the case of Darius Duvall, who was searched after a traffic stop and arrested despite having a concealed carry permit issued by the District of Columbia. (RELATED: US Territory With ‘Unconstitutional’ Gun Laws Is Having Rough Week In Court)
SAF filed an amicus brief today in the Supreme Court of Maryland supporting the petition for certiorari in Darius Duvall v. State of Maryland, challenging the state’s refusal to recognize valid, out-of-state carry permits.
The brief urges the Court to grant review and hold that… pic.twitter.com/uwExP9dQrJ
— SAF (@2AFDN) July 23, 2026
“Travelers from other states were usually allowed to carry their firearms concealed,” the groups argued in their “friend of the court brief. “The historical tradition of these ‘traveler’s exception’ laws is not some outlier, but overwhelming to the point that it justifies this Court summarily reversing the decision below. It is especially relevant here, given the Petitioner was arrested while traveling in a vehicle.”
Democratic Attorney General Anthony Brown’s office declined to comment when reached by the Daily Caller News Foundation. The gun-rights groups argued that recent Supreme Court decisions in Wolford v. Lopez and Hemani v. United States warranted a new look at the case.
“Interstate visitors are Americans, yet states like Maryland treat them as suspect foreigners that need to be re-vetted before exercising a fundamental right. As this brief will concisely show, our historical tradition demands exactly the opposite,” the gun rights groups said. “Several of the Amici joined a lengthier brief in the United States Supreme Court in support of certiorari on this very issue. While neither this Court nor the Supreme Court granted review in that matter, the recent decisions in Wolford and Hemani counsel certiorari in this case.”
The groups also cited litigation in Hawaii that listed dozens of state laws that historically gave travelers greater leeway in carrying concealed firearms.
“We’re going to keep up the pressure,” SAF Director of Legal Research and Education Konstadinos Moros told the DCNF, adding, “It’s not that we’re confident that any petition will necessarily be granted, but we’re just going to keep banging on that door in hopes that they do.”
