Some of you might have had the same reaction that I did to the Court's count of states in N.Y. State Rifle & Pistol Ass'n v. Bruen:
[T]he vast majority of States—43 by our count—are "shall issue" jurisdictions, where authorities must issue concealed-carry licenses whenever applicants satisfy certain threshold requirements, without granting licensing officials discretion to deny licenses based on a perceived lack of need or suitability. Meanwhile, only six States and the District of Columbia have "may issue" licensing laws, under which authorities have discretion to deny concealed-carry licenses even when the applicant satisfies the statutory criteria, usually because the applicant has not demonstrated cause or suitability for the relevant license. Aside from New York, then, only California, the District of Columbia, Hawaii, Maryland, Massachusetts, and New Jersey have analogues to the "proper cause" standard.
What's the missing state? The answer, turns out, is Vermont, because it has what some call "constitutional carry"—pretty much all law-abiding adults can carry concealed weapons without the need for a license—without even the option of getting a license. The other 24 "constitutional carry" states also have shall-issue licensing schemes, which is why they're included in the Court's count of 43. (Vermont used to be the only such state.)
