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Most southern states had laws that prevented concealed carry. However, these acts were primarily to avert abolitionists from fighting back, so they were never seriously considered by most of the general population. But by the conclusion of the civil war, almost all states followed a colloquial pattern of outlawing concealed carry. It was not until the 1911 passing of the Sullivan Law in New York that major controversy was sparked among the public about the restrictive stance imposed by many concealed carry laws. This became the first law to implement a “may issue” system for issuing concealed carry weapon (CCW) permits . “May-issue” laws provide authorities with the discretion to issue permits. There restrictive regulations contrasted with the common “shall-issue” laws in which states must issue a permit to the applicant given that they pass all basic statutory requirements. However, in the wake of ever-growing crime rates, many more states began to implement more “Sullivan-type legislation,” providing authorities with the ability to deny concealed carry permits to many more individuals (“History of Concealed”). Unfortunately, this trend has largely diverged over the past few decades as many states have returned to more remiss system of CCW permit distribution. Currently, only nine states maintain stringent “may issue” laws, while a whopping 18 states have limited discretion “shall issue” laws, 17 states sustain no discretion “shall issue” laws, and a staggering six states maintain laws that require no CCW permits for individuals to legally carry concealed firearms (“Concealed”). These distinct systems have fostered incredibly different crime rates, leading many to argue for national agreement among a more uniform CCW