Another cert. petition asks the Supreme Court to resolve the circuit split on this question.
The case is Rogers v. Grewal, which challenges New Jersey’s restrictive firearms carry license policy. There’s a split on the subject among lower courts; the details are a bit complicated, but the short version is that the First, Second, Third, and Fourth Circuits have upheld such restrictive policies, while the Seventh, Ninth, and D.C. Circuits, together with the Illinois Supreme Court have struck down some such policies. Several amicus briefs support the petition, including one signed by, among others, the California State Sheriffs’ Association, which “represents each of the fifty-eight California sheriffs.”