Last updated October 2026 · By Nick Hall, reads the state gun bills and the court dockets behind them for USA Gun Shop readers
Quick take: A federal judge has refused to block Maryland’s convertible pistol law, the one written around Glock-pattern handguns. His written opinion landed on October 5, 2026, and it leaves the sales ban on course to start on January 1, 2027. It is a ruling on a preliminary injunction, not a final verdict on the law.
- Ruling: Judge Richard D. Bennett denied both preliminary injunction motions in Bathras v. Moore (1:26-cv-02074) in a 45-page opinion and a one-page order dated October 5, 2026.
- Court: The US District Court for the District of Maryland, which heard argument on September 25, 2026 and ruled from the bench that day.
- Why it matters: The court found the covered pistols likely count as “Arms” under the Second Amendment’s plain text and still held that Senate Bill 334 fits the historical tradition of regulating excessively dangerous weapons.
- What’s next: The case continues toward the merits, and no notice of appeal was on the docket as of October 8, 2026.
On September 30, a federal judge in Connecticut blocked a similar law built around the same part, the cruciform trigger bar. Judge Bennett had already gone the other way from the bench five days before that, and on October 5 he put his reasons in writing. I read all 45 pages so you don’t have to. Here’s what he decided, what he left open, and what it means if you want a Glock in Maryland.
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Table of Contents
What Judge Bennett Actually Decided
The order is one page long. It says the plaintiffs’ “Motions for Preliminary Injunction (ECF Nos. 21, 29) are DENIED” and tells the clerk to send copies to the lawyers. Nothing else.
The reasoning sits in the 45-page memorandum opinion filed the same day in Bathras v. Moore and the consolidated Duffy v. Moore. It says the judge denied the motions from the bench at the close of argument on September 25, “promising an opinion to follow.”
There are eleven plaintiffs across the two cases, among them the National Rifle Association, Firearms Policy Coalition, Second Amendment Foundation and Maryland Shall Issue.
They sued Governor Wes Moore, Attorney General Anthony Brown and State Police Secretary Michael Jackson, each in his official capacity. And they asked for a lot: a facial challenge to the law “in its entirety as to all handguns with a cruciform trigger bar.”
The judge set the tone on page one. Blocking the law, he wrote, “would be an extraordinary exercise of this Court’s power in blocking a democratically enacted state law.”
Why the Maryland Glock Ban Survived Even Though Glocks Likely Count as Arms
The fight ran on the Supreme Court’s two-step Bruen test. Step one asks whether the Second Amendment’s plain text covers what the law restricts. If it does, step two makes the state show the law fits the country’s historical tradition of firearm regulation.
Step one went to the plaintiffs. Maryland argued these pistols are “excessively dangerous arms” outside the right altogether, and the judge did not buy it. “The machinegun convertible pistols here likely fall within the plain text of the Second Amendment,” he wrote, pointing to their “popularity among civilians and law enforcement.”
He described the guns as sitting in “a liminal space between the categories,” with the machine gun on one side and the handgun on the other. What decided it was that the law reaches “common handguns, regardless of their later criminal conversion.”
But step two went to the state. The binding precedent is Bianchi v. Brown, the 2024 decision in which the full Fourth Circuit upheld Maryland’s assault weapons ban, and Judge Bennett applied its reasoning here. The State, he found, “has shown that SB 334 fits within the historic tradition” of restricting dangerous weapons prone to criminal misuse.
Maryland’s lawyers walked the court from founding-era statutes that treated an armed crowd as a riot, through gunpowder storage caps like a 1784 New York law limiting a person to 28 pounds in any one place, to 19th century restrictions on bowie knives, slungshots and blackjacks, and on to the National Firearms Act of 1934 and the 1986 federal machine gun ban.
The plaintiffs called the gunpowder comparison silly. The judge answered that “it requires no strain of the imagination to find that the same founding-era lawmakers may well have responded to today’s concern about machinegun convertible pistols just as the Maryland General Assembly did.”
Their strongest card was common use: a handgun this popular can’t be banned. The court treated that as a step one question, already answered in their favor. Then it added a line gun owners will not enjoy, that “valid weapons regulations are designed to address an excessive danger, perhaps not only in spite of, but because of its commonality.”
The Numbers Maryland Put in Front of the Court
The opinion spends pages on the record the legislature built, and on declarations the State filed in the case. Police recoveries in Maryland involving at least one machine gun went from 30 in the four years from 2019 through 2022 to 292 from 2023 through 2026. The opinion calls that “an increase of 873%.”
Most of the machine guns in those recoveries, one declaration said, “are pistols that feature cruciform trigger bars.” Criminal charges tied to machine guns averaged about 14 a year from 2019 through 2022. They hit 202 in 2024, 278 in 2025 and 231 so far in 2026.
The other side is in the opinion too, which notes that “Glock pistols rank among the top-selling firearms in the U.S. civilian market.”
The plaintiffs also pointed out that Maryland’s own Handgun Roster Board had designated these pistols “useful for legitimate sporting, self-protection, or law enforcement purposes.” The judge’s reply was short: “The law evolves with emerging threats.”
Four Things the Ruling Does Not Decide
First, it is not a final judgment that the law is constitutional. A preliminary injunction ruling is a forecast, and the judge said he was making this one “without the full benefits of discovery and a trial on the merits.”
Second, it leaves a key factual fight open. The plaintiffs argue these pistols are not as simple to convert as the State claims. The court said they had not carried their burden yet on facts “which may be developed at a later stage on the merits.”
Third, it does not say which models are covered. The statute tells the Department of State Police to adopt regulations, “including publishing a list of prohibited machine gun convertible pistols.” The opinion quotes that duty and never says whether the list exists.
Fourth, it does not reach your safe. The ban’s verbs are manufacture, sell, offer for sale, purchase, receive and transfer. Possess is not among them, and the Maryland convertible pistol law carries its own exceptions, including transfers to immediate family.
The opinion also notes that the Supreme Court has agreed to hear challenges to the Illinois and Connecticut assault weapons bans, with argument scheduled for December 2, 2026. I’d bet that ruling matters more to this case than anything filed in the district court before then.
Why Connecticut Went the Other Way
On September 30, 2026, Judge Kari A. Dooley granted preliminary injunctions against Connecticut’s version of this law. That meant the Connecticut Glock ban was blocked the day before it took effect. Same trigger bar. Opposite result.
Both judges ended up at step two, and that is where they split. Connecticut accepted, for its motion only, that its law touches the Second Amendment’s plain text, then relied on founding-era “proving laws” requiring guns to be inspected before sale, combined with the history of machine gun bans. Judge Dooley found the proving laws did not match.
Maryland argued a different tradition, about dangerous weapons and criminal misuse, with a Fourth Circuit decision behind it that does not bind a court in Connecticut. Judge Bennett’s opinion never mentions the Connecticut order.
Neither ruling is the last word. Judge Dooley wrote that “upon further development of the record, the outcome may well be different.” If you live in Connecticut, the ban is on hold. If you live in Maryland, the clock is running.
What Maryland Buyers Should Do Before January 1
Section 4-305.2 of the Criminal Law Article, added by Chapter 771, says the prohibition applies “on or after January 1, 2027.” Until then it does not stop a sale, and every other rule in our Maryland gun laws guide still applies.
From that date, a violation is a misdemeanor carrying up to three years in prison, a fine of up to $5,000, or both.
If you already own one, the opinion describes the law as stopping covered models “from being transferred and sold after January 1, 2027.” It does not describe a ban on keeping one.
Dealers got a specific warning. The judge called their claimed losses “too vague and speculative” and noted they had not shown “that they will be unable to sell their existing inventories before then.” The premise is plain enough: shops can sell what they hold through December 31.
An appeal is possible. Federal law lets a party appeal an order refusing an injunction right away, that appeal would go to the Fourth Circuit, and the rules allow 30 days to file. As of October 8, 2026, the docket shows no notice of appeal, and the October 5 order is the newest entry.
The judge said a Glock is likely the kind of handgun the Second Amendment covers. He let the sales ban go ahead anyway. For now.
Frequently Asked Questions
Did a court block Maryland's Glock ban?
No. On October 5, 2026, Judge Richard D. Bennett of the US District Court for the District of Maryland denied both preliminary injunction motions in Bathras v. Moore and the consolidated Duffy v. Moore. His opinion says he first denied them from the bench at the hearing on September 25, 2026.
When does Maryland's convertible pistol ban start?
Chapter 771 of 2026 (Senate Bill 334) took effect on October 1, 2026. The prohibition in section 4-305.2(a) of the Criminal Law Article applies on or after January 1, 2027. From that date a person may not manufacture, sell, offer for sale, purchase, receive or transfer a machine gun convertible pistol, subject to the exceptions in the law.
Is the ruling in Bathras v. Moore final?
No. It denies a preliminary injunction, which is a prediction about the merits made before discovery and trial. The case continues in the district court. An order refusing an injunction can be appealed to the Fourth Circuit, and no notice of appeal was on the docket as of October 8, 2026.
Can I keep a Glock I already own in Maryland?
The prohibition in section 4-305.2(a) covers manufacturing, selling, offering for sale, purchasing, receiving and transferring a machine gun convertible pistol. Possession is not on that list. The law also lets a person who lawfully obtained and possesses one sell or transfer it to an immediate family member who is not prohibited from possessing a firearm.
Can I still buy a Glock in Maryland?
Until January 1, 2027, section 4-305.2 does not stop the sale, though every other Maryland handgun rule still applies. On or after January 1, 2027, buying a pistol that meets the definition of a machine gun convertible pistol is prohibited unless an exception applies.
Why did the judge refuse to block the law if Glocks are in common use?
The court agreed the covered pistols likely fall within the Second Amendment's plain text because they are popular handguns. It then held, at the second step of the Bruen test, that Maryland had shown the law fits the historical tradition of regulating excessively dangerous weapons prone to criminal misuse, following the Fourth Circuit's decision in Bianchi v. Brown.
Why was Connecticut's Glock ban blocked when Maryland's was not?
They are different laws in different courts. On September 30, 2026, Judge Kari A. Dooley found the founding-era proving laws Connecticut relied on did not match its ban and granted preliminary injunctions. Maryland relied on a different historical tradition and on Fourth Circuit precedent, and Judge Bennett denied the injunction. Both rulings are preliminary.
What is the penalty for violating Maryland's convertible pistol law?
A violation is a misdemeanor under the existing penalty in section 4-306 of the Criminal Law Article, with imprisonment of up to 3 years, a fine of up to $5,000, or both.
Related Reading
- Maryland Convertible Pistol Ban: Sales Stop January 1, 2027
- Connecticut Glock Ban Blocked by Federal Judge
- California Glock Ban Survives DOJ’s Injunction Bid
- Gun Groups Sue New York Over Its Glock Ban
- Maryland Gun Laws (2026): HQL, Wear and Carry Permit, AWB and Sensitive Places
- US Gun Laws by State: 2026 Legal Directory
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