Maryland’s Glock sales ban remains on track for January 1, 2027, after a federal judge recognized that the targeted handguns fall within the Second Amendment’s plain text but refused to block the law.
In an October 5 memorandum opinion, U.S. District Judge Richard D. Bennett explained his denial of preliminary injunctions in Bathras v. Moore, consolidated with Duffy v. Moore. Bennett had announced the denial from the bench on September 25.
The result leaves law-abiding Marylanders facing a ban on acquiring covered, factory-built semiautomatic pistols because criminals might illegally convert them into machineguns.
Five days before Bennett issued his written opinion, a Connecticut federal judge blocked a similar restriction. The two courts reached opposing preliminary outcomes on a question that should matter to every gun owner: Can the government prohibit a lawful handgun based on an illegal modification someone else might make?
What Maryland’s Glock Ban Does
SB 334 prohibits manufacturing, selling, offering for sale, purchasing, receiving or transferring a covered “machine gun convertible pistol” beginning January 1, 2027, subject to exceptions.
Its definition targets semiautomatic pistols with a cruciform trigger bar that can be readily converted using a separate pistol converter installed in place of the slide’s backplate. That reaches Glock and Glock-pattern handguns meeting the statutory definition.
Current owners generally may retain their pistols, and the law permits certain immediate-family transfers. But allowing existing owners to keep a gun does nothing for the Maryland resident who wants to buy that same protected handgun after the prohibition begins.
As AmmoLand explained in its coverage of the injunction request, a factory Glock fires one round per trigger pull. A conversion device is a separate component, already subject to federal and Maryland prohibitions, with narrow legal exceptions. The challenged ban reaches the lawful pistol before any conversion occurs.
Protected Handguns, Sweeping Historical Analogies
Bennett recognized that the law targets common handguns before criminal modification and concluded that the challenged conduct falls within the Second Amendment’s plain text. He nevertheless accepted Maryland’s historical defense, relying heavily on the Fourth Circuit’s Bianchi v. Brown decision upholding Maryland’s rifle ban.
The opinion draws connections between SB 334 and restrictions on armed groups, gunpowder storage, Bowie knives, slungshots, blackjacks, short-barreled firearms and machineguns. Bennett treated those laws as evidence of a broader tradition of regulating weapons associated with criminal abuse or extraordinary casualties.
That is an expansive route from regulating dangerous conduct and particular weapons to prohibiting commerce in an ordinary defensive handgun. A gunpowder-storage rule does not, by itself, establish that the government may stop peaceable citizens from buying Glocks.
AmmoLand’s earlier reporting on Maryland’s defense identified the central problem: The state’s theory judges the handgun according to a criminal configuration that does not exist when the lawful buyer purchases it.
Connecticut Judge Refused to Blame Lawful Handguns for Criminal Conversions
In Glock, Inc. v. Griffin and NSSF v. Griffin, U.S. District Judge Kari A. Dooley granted preliminary injunctions on September 30 against Connecticut’s convertible-pistol restriction. Her reasoning exposed the fundamental problem with these bans: A lawful semiautomatic handgun does not lose its constitutional protection because a criminal might later modify it.
Connecticut tried to justify its prohibition by combining Founding-era firearm inspection requirements with restrictions on machineguns. But Dooley identified the gap in that argument. Historical inspection laws ensured that firearms were safely manufactured and operable when sold. They did not establish a tradition of banning safe, functional firearms because someone might subsequently misuse or illegally alter them.
That distinction matters. An unmodified Glock is a semiautomatic handgun. Installing a separate conversion device changes the firearm—and the legal question. Connecticut sought to use restrictions on the resulting machinegun to justify prohibiting the ordinary handgun before any criminal conversion occurred.
The judge emphasized that the targeted, unconverted handguns are safe, extremely popular for self-defense and protected by the Second Amendment. On the record before her, Connecticut had failed to demonstrate a historical tradition sufficient to overcome the presumption that its ban was unconstitutional.
For gun owners, that is the critical difference between the two decisions. Dooley required Connecticut to justify restricting the lawful handgun itself. Bennett accepted Maryland’s broader historical theory that susceptibility to criminal conversion could justify blocking future transactions in that same category of protected arms.
Connecticut’s decision preserves a principle Maryland’s ban undermines: Peaceable Americans should not lose access to constitutionally protected handguns because criminals break laws that already prohibit illegal conversion.
Criminal Misuse Does Not Cancel the Second Amendment
A factory Glock is a semiautomatic handgun. It does not become a machinegun because Maryland politicians give it a new label, and its owner’s rights do not disappear because a criminal might install an illegal device.
Maryland’s approach makes peaceable gun owners pay for crimes they have not committed. Allowing current owners to keep their pistols does not cure that infringement. The right to keep and bear arms cannot survive if the government can prohibit the next buyer from acquiring them.
Bennett recognized that these handguns fall within the Second Amendment’s plain text, then accepted a collection of historical restrictions as justification for cutting off access to them. Gunpowder-storage rules and restrictions on Bowie knives should not become permission slips for banning ordinary defensive handguns.
The stakes extend well beyond Glock. Accept potential criminal modification as grounds for a ban, and anti-gun lawmakers will have another argument to deploy against the next firearm on their list.
“Shall not be infringed” is a command to government. Maryland does not get to turn a criminal’s illegal conduct into a law-abiding American’s lost constitutional right.
About Duncan Johnson:
Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor and editor-in-chief for AmmoLand News and is responsible for AmmoLand’s daily gun-rights reporting and industry coverage.
