Also known as "Permitless Carry", refers to a State's laws that allow a law-abiding citizen who may otherwise own, purchase, and possess firearms under both state and federal law to conceal a firearm on their person without having to apply for a Concealed Carry Permit from their local or state government. The idea of "Constitutional Carry" follows the premise that the U.S. Constitution's Second Amendment recognizes every American's inherent right to "keep and bear arms" for their own personal protection. Individual gun ownership both inside and outside of one's home was also recognized by the U.S. Supreme Court's decisions in District of Columbia v. Heller (2008) and New York State Rifle and Pistol Assn., Inc. v. Bruen (2022). Alaska was the first state in the Union to implement permitless (Constitutional) carry in 2003, modeling their laws after the state of Vermont which historically has never had a law regulating how one carries their firearms since its statehood. Thus, "Constitutional Carry" is sometimes also called "Vermont Carry".