On Monday, April 21, the U.S. Supreme Court declined to review an appeal from the state of Minnesota in Worth v. Jacobson, allowing to stand an Eight Circuit ruling declaring that a ban on obtaining carry permits by 18-20 year olds is unconstitutional. This paves the way for these military-aged adults to apply for permits from their local sheriffs.
The Worth case was initially filed in June 2021 and included as plaintiffs three young adults challenging Minnesota’s permit to carry age limit. In 2023, a federal district court ruled the restriction was unconstitutional in light of the U.S. Supreme Court’s ruling in NYSRPA v. Bruen. Later that year, a three-judge panel of the United States Court of Appeals for the Eighth Circuit unanimously found that Minnesota’s ban against 18–20-year-olds seeking permits to carry handguns for self-defense is indeed unconstitutional and reiterated that the ban could not survive the Bruen standard of evaluating the restriction for consistency with an historical tradition dating our nation’s founding era. “Minnesota has not met its burden to proffer sufficient evidence to rebut the presumption that 18 to 20-year-olds seeking to carry handguns in public for self-defense are protected by the right to keep and bear arms,” the court wrote.
NRA-ILA has been advocating on behalf of the rights of young adults for decades and previously filed an amicus brief supporting the challenge to the Minnesota carry ban. We also reported on the subsequent legal win in the appeals court here: NRA-ILA | Appeals Court: 21+ Age Requirement for Carry Permits is Unconstitutional
Meanwhile, the NRA is pursuing this issue in other jurisdictions as well.
This past February, NRA filed Escher v. Noble, challenging Massachusetts’s prohibition on the possession and carry of handguns and semiautomatic firearms by adults under 21.
A similar case, Young v. Ott, is currently before the U.S. District Court for the Western District of Pennsylvania, where NRA is challenging Pennsylvania’s prohibition on concealed carry by 18 to 20-year-olds.
Recently, the Fifth Circuit Court of Appeals held that 18 U.S.C. §§ 922(b)(1) and (c)(1)—which prohibit federal firearms licensees from selling handguns to 18 to 20-year-olds—violate the Second Amendment. In its opinion, the court repeatedly cited law review articles published by NRA-ILA’s Director of Litigation Counsel, Joseph Greenlee, in determining that 18-to-20-year-olds are among “the people” and were protected by the Second Amendment at the time of our nation’s founding.
In Florida, NRA challenged the state ban on firearm purchases by adults under 21. Last month, the en banc Eleventh Circuit upheld the ban in an 8-4 decision. Yet soon after the court issued its decision, Florida’s Attorney General announced his office would not defend the law if NRA sought further review at the U.S. Supreme Court. Additionally, legislative efforts in Tallahassee are ongoing to pass legislation to restore the ability for young adults to lawfully purchase firearms.
Also on the legislative front, Iowa Governor Kim Reynolds recently signed legislation which will allow 18-20 year-olds to own and carry handguns in Iowa beginning July 1, 2025.
Ultimately, these critical developments have aided the more thorough and appropriate application of the Second Amendment to include 18 to 20-year-olds. Simply put, courts are increasingly recognizing that young adults are among “the people” whose right to keep and bear arms is protected. Whether the U.S. Supreme Court will eventually take up the issue on the merits remains to be seen, but last week’s denial of cert in Worth means another pro-gun decision will stay on the books as binding law.
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