But she is absolutely correct.
I'm too lazy to go look up the citation, but the Circuit that covers New York just ruled that their "may issue" laws were perfectly fine and dandy, as (I seem to recall but with a lot less certainty) did the Ninth regarding California's system.
The conflict between Circuits is, IMHO, a good thing. It will not force SCOTUS to weigh in on the mastter, and SCOTUS is going to be bound by their decisions in Heller and McDonald. Remember, SCOTUS will either have to agree that the rigfht, although clearly extending to the home, also extends outside the home or it will have to do some fancy dancing to now refute both he implications and actual pronouncements of the Justices. Admittedly the question in Heller and McDonald only addressed keeping and bearing in the home, but the Justices went beyond the threshold when writing their opinions.