In summary, although we assume that Appellee Woollard's Second Amendment right is burdened by the good-and-substantial-reason requirement, we further conclude that such burden is constitutionally permissible. That is, under the applicable intermediate scrutiny standard, the State has demonstrated that the good-and-substantial-reason requirement is reasonably adapted to Maryland's significant interests in protecting public safety and preventing crime.

Gun control has been the center of attention since the Newtown, Connecticut shooting [WSJ backgrounder] in December. Earlier this month US Attorney General Eric Holder [official website] spoke before Congress [JURIST report] urging [text] them to pass gun control legislation. Also this month the Maryland Senate approved a different bill [JURIST report] that would make it harder to get a gun license. In mid-January, President Barack Obama signed 23 executive orders [JURIST report] intended to strengthen existing gun laws and urge Congress to reinstate the assault weapons ban that expired in 2004. The previous day New York Governor Andrew Cuomo [official website] signed legislation [JURIST report] intended to impose tighter restrictions on gun and ammunition sales, banning any magazine that can hold more than seven rounds and implementing instant background checks on all ammunition purchases at the time of sale.