Rhode Island Court Rules: States Can Pick Open OR Concealed Carry (But Not Both)

A federal court in Rhode Island just handed down a decision that's going to shape carry rights across the country – and honestly, it's exactly what I expected to happen, even though it's not what I wanted to happen.

In O'Neal v. Noona, Judge William Smith ruled that Rhode Island can restrict open carry as long as they allow concealed carry. Six Rhode Island gun owners sued because they had concealed carry permits but were denied the “unrestricted” permits that would let them open carry. They lost.

Here's What Rhode Island Does

Rhode Island has this weird two-permit system:

• Regular permits: Basically shall-issue concealed carry. Meet the requirements, get the permit.
• Unrestricted permits: Totally discretionary. These let you open carry, but good luck getting one.

The plaintiffs had the concealed carry permits but wanted the choice to open carry too. The court said nope.

How This Decision Was Made

Look, the Supreme Court has been pretty clear since Bruen: Americans have the right to carry guns in public for self-defense. But here's the key – they never said you get to pick HOW you carry.

The Supreme Court specifically noted that historically, states could ban concealed carry as long as they allowed open carry. Rhode Island just flipped it – they're saying you can conceal carry but not open carry. Same principle, different direction.

Judge Smith basically said: “The Second Amendment gives you the right to bear arms in public. Rhode Island lets you do that with concealed carry. That's enough.”

My Take: This Stinks, But It's Where We Are

Personal opinion? I think the second amendment protects your rights to both open carry and concealed carry, and gun owners should get to decide what works best for them. Want to open carry? Go for it. Prefer concealed? That's your call.

But that's not where the courts are heading. This decision is going to encourage more states to restrict open carry, knowing they can get away with it as long as they have some form of shall-issue concealed carry.

What This Means Going Forward

This ruling is probably going to become the template nationwide. Expect to see:

• More states restricting open carry while maintaining concealed carry options
• Courts consistently ruling that one form of carry satisfies the Second Amendment
• The end of arguments that you have a constitutional right to choose your carry method

It's frustrating if you're an open carry advocate, but it's the reality of where Second Amendment law is right now. The Supreme Court gave states a roadmap in Bruen, and Rhode Island (and other states) are following it.

The Bottom Line

States get to pick for now: open carry OR concealed carry. They don't have to offer both. As long as there's a meaningful way to carry in public, the Second Amendment box is checked.

Is it ideal? Not in my book. But it's what we're working with until the Supreme Court says otherwise – and this could very well be the next big Second Amendment case headed to SCOTUS. We got the right to have guns in our homes with Heller, the right to carry in public with Bruen, and maybe the next case will clarify that Americans should have both concealed and open carry options.

For more on the differences between open and concealed carry, check out our guides on concealed carry vs. open carry and open carry laws across the United States.