The Fourth Circuit Court has upheld Maryland's 'permit to purchase' law, requiring a license before buying a firearm. This decision, in Maryland Shall Issue v. Moore, relies heavily on dicta from the Supreme Court's Bruen decision, interpreting 'shall issue' licensing laws as presumptively constitutional. The court established a new test where the burden shifts to plaintiffs to prove such laws infringe on Second Amendment rights, potentially bypassing historical analysis.
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