How did Worth v. Jacobson and subsequent federal rulings change age eligibility and other procedural requirements for Minnesota carry permits?
Executive summary
Worth v. Jacobson began as a 2021 challenge to Minnesota’s rule that only people 21 and older could obtain permits to carry loaded handguns in public and, after unanimous rulings below and the Supreme Court’s denial of review, placed 18–20‑year‑olds squarely within the class eligible to apply for Minnesota permits to carry [1] [2] [3]. The Eighth Circuit’s application of the Supreme Court’s Bruen historical‑tradition framework and the ensuing certiorari denial cemented that Minnesota’s 21+ age floor is unconstitutional as applied to 18–20‑year‑olds and produced knock‑on effects for state statute text and interstate reciprocity [2] [4] [5] [6].
1. How the litigation progressed and what courts decided
The suit was filed in June 2021 by three young adults together with gun‑rights groups, challenging Minn. Stat. §624.714’s 21‑year minimum; a federal district court granted summary judgment to plaintiffs and the Eighth Circuit affirmed that the age restriction could not survive the Bruen standard, finding Minnesota failed to show historical analogues supporting the 21+ rule [2] [7]. Minnesota’s Attorney General sought Supreme Court review, but the justices denied certiorari, leaving the Eighth Circuit judgment intact and effective law in the circuit [8] [1] [3].
2. The legal reasoning: Bruen’s historical‑tradition test applied to age limits
Under the framework articulated in New York State Rifle & Pistol Ass’n v. Bruen, courts ask whether modern regulations are consistent with the Nation’s historical tradition of firearm regulation; the Eighth Circuit concluded Minnesota could not identify historical analogues showing a tradition of excluding 18–20‑year‑olds from public carry, and criticized reliance on inapposite sources like the Militia Act of 1792 [2] [7]. Opponents of the decision—advocacy groups and amici defending the statute—argued that later‑era regulations and Reconstruction‑era restrictions provide analogues and that Bruen does not require identical historical matches, a point Everytown and other groups raised in briefs [7] [9].
3. Concrete change to age eligibility in Minnesota law
Practically, the rulings mean that law‑abiding adults aged 18–20 may apply for and receive a Minnesota permit to carry where they previously could not; state statutory text now carries a Revisor note recognizing that the 18–20 prohibition was found unconstitutional [5] [10]. Multiple gun‑rights organizations and local reporting confirmed county sheriffs began accepting applications from 18–20‑year‑olds after the appellate mandate and following the Supreme Court’s denial of review [3] [10].
4. Procedural ripple effects beyond the age floor—applications, reciprocity, and enforcement
The court rulings did not invent new licensing mechanics, but they altered who is included in the application pool and affected Minnesota’s reciprocity calculus: because Minnesota now issues permits to 18–20‑year‑olds, the Department of Public Safety’s reciprocity assessments and private reciprocity trackers treated Minnesota as more aligned with states that already allowed young adult permits, prompting updates in interstate recognition and travel guidance [6]. The statute continues to channel applications through county sheriffs and to retain other procedural elements (background checks, disclosures to officers), but the inclusion of 18–20‑year‑olds means sheriffs must process their applications under the same procedural framework already in place [5] [10].
5. Political, advocacy, and practical consequences—competing narratives and agendas
Gun‑rights groups hailed the outcome as a vindication of young adults’ Second Amendment rights and a precedent for similar challenges elsewhere, while public‑safety advocates and groups like Everytown framed the decision as a narrowing of states’ room to regulate in the name of safety and argued for different historical readings—reflecting predictable advocacy interests on both sides [1] [11] [9]. The NRA, SAF, and other plaintiffs openly celebrated enforcement changes and signaled plans to press parallel suits in other states; Minnesota officials, including the Attorney General, pursued Supreme Court review before the denial, signaling continued political disagreement over policy even after the litigation ended [12] [8] [11].
6. Limits, caveats, and open legal questions going forward
The rulings resolve the 21+ permit ban in Minnesota for now but do not create a nationwide rule beyond the Eighth Circuit; the Supreme Court’s denial leaves the Eighth Circuit precedent binding in that circuit but not controlling elsewhere, and substantial doctrinal disputes over how broadly Bruen’s historical test applies remain contested in other suits and circuits [4] [2]. Reporting and the statute note document the change in eligibility and immediate administrative consequences, but sources do not provide exhaustive detail on how every sheriff’s office altered internal workflows or how enforcement will play out in nuanced factual contexts—areas where on‑the‑ground practice may diverge from the jurisprudential framework [5] [10].