Christopher Paris, Commissioner, Pennsylvania State Police v. Second Amendment Foundation, et al.
SecondAmendment DueProcess Privacy JusticiabilityDoctri
Do firearms laws imposing a minimum age of 21 violate the purported Second Amendment rights of 18-to20-year-olds?
The federal government and 32 states establish 21 as the minimum age for certain gun rights . Since United States v. Rahimi , five courts of appeals have considered whether these widespread laws violate the purported Second Amendment rights of 18 -to-20-yearolds. Those Courts are sharply divided in both method and result. The Tenth and Eleventh Circuits held that restrictions on 18 -to-20-year-olds are constitutional, relying on Founding -era common law principles that prevented anyone und er the age of 21 from purchasing weapons. Rocky Mountain Gun Owners v. Polis , 121 F.4th 96 (10th Cir. 2024) ; Nat’l Rifle Ass’n v. Bondi , 133 F.4th 1108 (11th Cir. 2025) (en banc), cert . pending sub nom. , Nat’l Rifle Ass’n v. Glass, 24-1185 (U.S.). Those courts also looked to post -enactment history to confirm their understanding of the Founding -era evidence . Ibid. But the Third, Fifth, and Eighth Circuits reached the opposite conclusion when examining the same history. App.1a -52a; Reese v. Bureau of Alcohol , Tobacco, Firearms, and Explosives, 127 F.4th 583 (5th Cir. 2025); Worth v. Jacobson , 108 F.4th 677 (8th Cir. 2024), cert. denied , 24-782 (U.S.). This Court ’s review is necessary to resolve this acknowledged split on an important, recurring issue . Law enforcement officials need clarity before the confusion deepens. The question presented is: Do firearms laws imposing a minimum age of 21 violate the purported Second Amendment rights of 18 -to20-year-olds?