The U.S. Supreme Court’s landmark decision in District of Columbia v. Heller held that the prohibition of handguns in the home was unconstitutional and the Court extended this holding to the states through the Fourteenth Amendment in McDonald v. City of Chicago. Through these cases, the Court clarified that the core of the Second Amendment was self-defense. However, it did not specify the scope of this self-defense “core” and left the lower courts with room for interpretation—for example, it is unclear whether and to what extent the Second Amendment applies to the public space. Furthermore, the Supreme Court did not provide a standard of review for lower courts to apply when weighing the constitutionality of gun regulations. Lastly, while the Court relied heavily on the nation’s history to justify its holding in Heller, it did not give any further guidance regarding the sources of history that the Court deemed most reliable.

Given these ambiguities, states have implemented statutes that require law-abiding citizens interested in obtaining a handgun license for concealed public carry to articulate a specified need for self-defense. Lower courts had generally accepted such provisions as constitutional until the D.C. Circuit in Wrenn v. District of Columbia held otherwise.

This Note analyzes the constitutionality of these provisions. It attempts to clarify some of the Supreme Court’s ambiguities through its analysis and ultimately proposes that these state statutes are constitutional.