I think court rulings have come together to infer that some form of carry must be allowed - though open, concealed or both - and permitted or permit-less is up to the State. As we know, it still has not yet been litigated out fully... I get frustrated with cases that ask for one or the other - we should be asking for either from States that make permit issuance nearly impossible. Keep your restrictive permit for concealed carry as long as unlicensed open is allowed...
Which Federal Appellate courts and which state high courts have held that there is a Second Amendment right to concealed carry post-Heller?
These Federal Appellate courts say there isn't:
Hightower v. City of Boston, 693 F. 3d 61 - Court of Appeals, 1st Circuit (2012)
Kachalsky v. County of Westchester, 701 F. 3d 81 - Court of Appeals, 2nd Circuit (2012)
Drake v. Filko, 724 F. 3d 426 - Court of Appeals, 3rd Circuit (2013)
Woollard v. Gallagher, 712 F. 3d 865 - Court of Appeals, 4th Circuit (2013)
National Rifle a**'n v. Bureau of Alcohol, Tobacco, 700 F. 3d 185 - Court of Appeals, 5th Circuit (2012)
National Rifle a**'n of America, Inc. v. McCraw, 719 F. 3d 338 - Court of Appeals, 5th Circuit (2013)
US v. Sanford, 707 F. 3d 594 - Court of Appeals, 6th Circuit (2012)
Moore v. Madigan, 702 F. 3d 933 - Court of Appeals, 7th Circuit (2012)
US v. Fincher, 538 F. 3d 868 - Court of Appeals, 8th Circuit (2008)
Peruta v. San Diego en banc 9th Circuit (2016)
Peterson v. Martinez, 707 F. 3d 1197 - Court of Appeals, 10th Circuit (2013)
Heller v. District of Columbia (Heller II), 670 F. 3d 1244 - Court of Appeals, Dist. of Columbia Circuit (2011)
Parker v. District of Columbia 478 F.3d 370 (D.C. Cir. 2007) was affirmed under the name of District of Columbia v. Heller and no DC criminal court of appeals has tossed out a concealed carry case in which the defendant alleged that he has a Second Amendment right under Heller to carry a concealed weapon.
The only Federal court of appeals not to weigh in has been the 11th Circuit. Of the three states in the 11th Circuit, the Georgia Supreme Court reaffirmed its holding in Nunn v. State (cited in Heller) which held that concealed carry is not a right in HERTZ V. BENNETT 751 S.E.2d 90 (Ga. 2013). We are waiting for the Florida Supreme Court (in the 11th Circuit) to have its say about concealed/open carry in Norman v. State
Not a single Federal Circuit nor state high court has held, implied, or remotely suggested that "some form of carry must be allowed - through open, concealed or both..." They have all said that concealed carry is not a Second Amendment right even in cases where concealed carry was not at issue.
And then there are the state high courts which have held that concealed carry is not a Second Amendment right...
Concealed carry is of no use to me because I don't carry a purse or wear a dress, and I'm not into secret advantage and unmanly assassination.
"Should the Open Carry movement become successful it will result in the greatest dissolution of government power since the collapse of the Soviet Union." - Charles Nichols
"If a monkey looks into a book, a sage cannot look out." - Georg Christoph Lichtenberg
"La plus belle des ruses du diable est de vous persuader qu'il n'existe pas." - Charles Baudelaire
"God doesn't want me and the devil isn't finished with me." - Raymond Reddington
"When you lift the last veil, you might discover that your bride is an ignorant, illiterate child living in a world of fear and superstition." - Charles Nichols.*
* I posted this on my Facebook page on May 20, 2011. Unable to find its origin, I claim to be its creator.