Good discussion of DC Circuit's recent 2A ruling

In Wrenn, a divided panel of the D.C. Circuit struck down the district’s permitting scheme, which required those seeking to publicly carry a concealed weapon to first show a “proper reason” for doing so.

Such requirements raise interesting constitutional questions, but have been universally upheld by other courts, meaning that this week’s decision creates — for the moment, at least — an arguable circuit split.

Is he right about that "universally upheld"? IANAL, but that's not the way I remember things.