You mean like MD increasing the cost and putting self-defense out of reach for low-income citizens who need it most?Another issue which could push the courts in that direction is these anti states are making it more and more difficult to get a permit, even with the need requirement gone.
Many charge more for out of state residents (some like CA and NY don’t even issue), and according to Handgunlaw for MA a non resident has to apply in person in Chelsea, which is near Boston. A VT resident would have to drive clear across the state to get the permit.
They can’t have it both ways where they require the permit yet make it as difficult as possible. Scotus may just say screw it at some point and tell these states you had your chance but chose to be obstructionists so your permit schemes are out the window.