Court Doubles Down on DC’s Holster-on-Person Requirement
Washington, DC’s concealed carry landscape just saw a significant federal court ruling that doubles down on the city’s holster-on-person requirement for licensed handgun carriers. On September 24, 2025, in Russell et al. v. District of Columbia (D.D.C., No. 24-1820), a U.S. District Court held that the District may continue requiring concealed carry licensees to carry their pistols holstered on their body rather than off-body (like in a purse, bag, or vehicle), rejecting the plaintiffs’ constitutional challenge under the Second Amendment.
D.C. Concealed Carry Ruling: Court Upholds Holster-On-Person Requirement in Russell et al. v. District of Columbia
In Russell, several concealed carry license holders challenged DC’s regulation that a pistol must be carried in a secure holster on the person. Plaintiffs, including non-resident licensees who frequent DC, argued they should be able to carry their firearms off-body—for example:
❌ Inside a purse or handbag
❌ In a backpack or sling bag
❌ In a vehicle glove box or console
They claimed the holster-on-person rule unduly burdens their right to bear arms for self-defense under the Second Amendment.
The Court’s Decision: What It Means
The federal court granted summary judgment to the District of Columbia, upholding the holster requirement. The judge emphasized:
DC may regulate the manner of carry as part of its concealed carry licensing framework.
The holster-on-person rule is not an effective denial of the right to bear arms, but a modest, public-safety-oriented burden on carry methods.
The city’s historical tradition of regulating how firearms are carried supports this exercise of regulatory authority.
Put simply: DC can require concealed carry licensees to keep their handguns holstered on their bodies instead of off-body or in a vehicle, at least under the legal standards applied in this case.
Why This Matters for Concealed Carriers
This ruling confirms that:
Holster requirements are enforceable in DC.
Licensees who carry off-body could risk licensing penalties or criminal charges if caught violating the rule.
DC’s concealed-carry regulations remain among the most detailed in the nation.
While some jurisdictions focus on where you may carry, D.C. goes further by dictating how a licensed concealed firearm must be carried—specifically on the carrier’s person in a secure holster. This can have practical impacts for residents and visitors alike who travel through the District.
How This Connects to Broader Gun Law Trends
Russell joins a broader chronology of challenges to D.C.’s gun rules:
In 2008, District of Columbia v. Heller established an individual right to possess firearms for self-defense, striking down an outright handgun ban.
Earlier cases like Wrenn v. D.C. invalidated “good-reason” requirements for concealed carry permits, reinforcing that licensing schemes must enable meaningful exercise of the right.
Russell now clarifies that once a lawful license is obtained, D.C. can still regulate manner of carry in ways courts find consistent with public safety.
This means that even under post-Bruen doctrine, where courts evaluate firearm regulations against historical traditions of regulation, reasonable manner-of-carry rules can survive constitutional challenge.
Practical Takeaways for Gun Owners
If you hold—or plan to get—a concealed carry license in DC:
Expect to carry any concealed handgun on your person in a secure holster.
Off-body carry (purse, bag, console) can be seen as a violation of DC regulations.
Penalties for non-compliance may include license revocation or criminal liability.
Stay updated—laws and court interpretations continue to evolve.
Final Thoughts
The Russell et al. v. District of Columbia decision reaffirms DC’s authority to regulate not just concealed-carry licensing, but also the specific manner in which a handgun must be carried by a licensee. Gun owners and legal watchers should monitor how other courts treat similar “manner-of-carry” rules as challenges continue nationwide.
Disclaimer: Firearms laws and procedures can change. Always verify current requirements with the Maryland State Police before applying.
Sources:
RUSSELL et al v. DISTRICT OF COLUMBIA et al, No. 1:2024cv01820 - Document 47 (D.D.C. 2025) :: Justia
Gun laws in the District of Columbia - Wikipedia
https://en.wikipedia.org/wiki/District_of_Columbia_v._Heller
https://en.wikipedia.org/wiki/Wrenn_v._District_of_Columbia
https://news.bloomberglaw.com/litigation/dc-can-require-gun-holders-to-carry-weapons-on-their-bodies
