We’ve seen constitutional carry roll across the country in a big way from Vermont’s old-school, no-permit tradition to 29 states today where responsible adults can carry concealed (and usually openly) without jumping through government hoops. But this isn’t the first big wave of change in concealed carry laws. Before permitless carry took off, there was the shall-issue revolution that started changing the game back in the late ’80s. Both movements pushed toward more freedom for self-defense, but they happened in different times, with different people leading the charge and different speeds.
How Shall-Issue Got Started: Florida in 1987
Florida was the real turning point. Before 1987, most states either banned concealed carry outright, made it super restrictive with “may-issue” rules (where sheriffs or officials could say no for almost any reason), or had very limited systems. A few places had shall-issue earlier—Indiana in 1980, Maine and North Dakota in 1985, South Dakota in 1986 – but they were the exceptions.
Then Florida passed the Jack Hagler Self Defense Act in 1987 under Gov. Bob Martinez. It set up a statewide shall-issue concealed weapons permit: if you passed a background check, had no violent felonies, and met basic mental-health standards, the state had to issue the permit. No more begging for “good cause” or hoping the local sheriff liked you. It became the blueprint that showed the rest of the country what was possible.
A huge part of making it happen was Marion Hammer. As the NRA’s top lobbyist in Florida (and later the first woman to serve as NRA president), she worked through Unified Sportsmen of Florida to rally support, fight the opposition, and get the bill across the finish line. Her energy and persistence turned Florida into proof that shall-issue carry could work without turning streets into war zones. (Florida’s violent crime actually trended down nationally after the early ’90s peak, which helped quiet the critics.)
After Florida, the idea caught fire:
- Late ’80s and early ’90s: Georgia, Oregon, Pennsylvania, West Virginia, Idaho, Mississippi, Montana.
- Mid-’90s: Alaska, Arizona, Tennessee, Wyoming, Arkansas, Nevada, North Carolina, Oklahoma, Texas, Utah, Virginia.
- 2000s: Michigan (2001), Colorado, New Mexico, Minnesota, Missouri, Ohio, Kansas, Nebraska, Iowa, Wisconsin.
- 2010s: Illinois finally joined in 2013 after court pressure.
By the early 2010s, more than 40 states had shall-issue or better laws, covering most Americans. It was a lot of grassroots work, NRA lobbying, state legislators listening to voters who wanted real self-defense options, and hard data showing responsible carry didn’t cause more crime.
Constitutional Carry: Building on That Foundation (2000s–Now)
Constitutional carry (permitless carry) picked up right where shall-issue left off. Vermont had always done it – no permit ever required for concealed carry. Alaska became the first modern state to drop its permit requirement in 2003.
The real explosion started later, mostly in states that already had shall-issue in place:
- 2010s: Arizona (2010), Wyoming (2011), then Kansas, Maine, Idaho, Mississippi, West Virginia, Missouri, New Hampshire, North Dakota.
- 2019–2021: Kentucky, Oklahoma, South Dakota, Arkansas, Iowa, Tennessee, Texas, Montana, Utah.
- 2022–2024: Alabama, Ohio, Indiana, Georgia, Florida (2023), Nebraska, Louisiana, South Carolina.
As of February 2026, 29 states let eligible adults carry concealed without a permit (usually 21+, with some allowing 18+ for military or residents). The Supreme Court’s 2022 Bruen decision—which struck down subjective “may-issue” rules—gave even more momentum, pushing restrictive states toward shall-issue while encouraging others to go all the way to permitless.
How the Two Compare
- Speed: Shall-issue took 30–40 years to spread from Florida’s big win to most of the country. Constitutional carry has moved much faster in the last decade or so, adding states quickly once the culture and courts caught up.
- Who drove it: Shall-issue was often top-down: strong lobbying (like Marion Hammer and the NRA), big legislative fights, and proving the concept worked safely. Constitutional carry has a more bottom-up feel in many places: everyday people pushing, post-Bruen confidence, and the realization that shall-issue training and checks weren’t adding much for law-abiding folks.
- Facing the critics: Both got hit with the same “blood in the streets” warnings. Shall-issue proved them wrong with real-world numbers; constitutional carry is riding that same wave of evidence.
- Where we stand now: Shall-issue laid the groundwork (almost every permitless state started there). Today, roughly 29 permitless carry states plus another 12–13 shall-issue states (where permits are required but issued objectively if you meet clear criteria) mean more than 40 states now honor broad carry rights compared to the heavily restrictive map of the 1980s. The remaining 8–9 states plus DC are the former ‘may-issue’ holdouts (California, Connecticut, Delaware, Hawaii, Maryland, Massachusetts, New Jersey, New York, and sometimes Rhode Island is grouped here). Post-Bruen, even these have had to shift to shall-issue frameworks on paper removing subjective ‘good cause’ requirements, though many added new restrictions (like expanded sensitive-places bans, high fees, or lengthy training) that make access harder in practice. Ongoing lawsuits continue to challenge those additions.
The common thread through all of it is simple: steady advocacy, solid results, and more Americans exercising their constitutional rights. From Vermont’s quiet tradition to Florida’s shall-issue breakthrough to today’s permitless wave, we’ve come a long way.
Where Do We Go from Here?
Looking ahead, the momentum feels strong for more progress. With 29 states already on board for constitutional carry and no real backsliding in any of them the question isn’t if we’ll see more, but which ones and how soon. States like North Carolina have seen bills filed repeatedly (and come close), and places with Republican majorities and pro-2A governors could be next in line. Michigan’s seen push from lawmakers and candidates talking about dropping permit requirements entirely. Even in some shall-issue holdouts, post-Bruen court challenges keep chipping away at restrictions.
On the federal side, bills like the Constitutional Concealed Carry Reciprocity Act (H.R. 38) keep getting reintroduced, aiming to let valid carry from one state work nationwide, though that’s a tougher hill to climb with divided Congress. If it ever passes, it could flip the script on the remaining restrictive states overnight.
Bottom line: the trend is clear. As more data rolls in showing permitless carry doesn’t spike crime, and as public support for Second Amendment rights holds steady (or grows), we’re likely to see the map keep filling in. It might not happen everywhere, but in red-leaning or swing states with the right politics, don’t be surprised if the number climbs to 35 or higher in the coming years.
