Duvall v. Maryland Brief: Protecting the Right to Interstate Travel While Armed

Matthew Cavedon

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.

Cato joined an amicus brief authored by the Second Amendment Foundation and other gun rights groups urging the Maryland Supreme Court to address the issue. Just a few years ago, the Supreme Court confirmed that the Second Amendment protects “the general right to publicly carry arms for self-defense.” That right cannot tolerate each state having the power to force individuals from every other state to jump through time-consuming and often costly hoops before a state deigns to allow them to carry a firearm within its borders. 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 concisely shows, our historical tradition demands exactly the opposite.