The Second Amendment Foundation (SAF), alongside its partners, has filed a response brief with the U.S. Supreme Court in the case of Jacobson v. Worth, urging the justices to grant full review and settle a critical dispute over the concealed carry rights of young adults aged 18-20 in Minnesota.
The filing comes as part of a broader effort to clarify whether the Second Amendment fully extends to this age group, amidst conflicting rulings from lower courts.
Originally filed in June 2021 as Worth v. Harrington, the case challenges Minnesota’s prohibition on issuing concealed carry permits to individuals under 21. SAF, joined by the Minnesota Gun Owners Caucus, the Firearms Policy Coalition, and individual plaintiffs Kristin Worth, Austin Dye, and Axel Anderson, secured victories at both the federal district court and the Eighth Circuit Court of Appeals.
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Despite the plaintiffs aging out of the 18-20 range, the Eighth Circuit allowed Joe Knudsen to join the case, ensuring its continuation. The legal team, led by David H. Thompson, Peter A. Patterson, John D. Ohlendorf, and William V. Bergstrom of Cooper & Kirk in Washington, D.C., now seeks a definitive ruling from the nation’s highest court.
Minnesota, appealing the Eighth Circuit’s decision, has also petitioned the Supreme Court to take up the case. In a rare alignment, SAF agrees with the state’s request for review—not to defend the ban, but to solidify the constitutional rights of young adults nationwide.
“Today’s filing is unique in that we are agreeing with Minnesota’s request in asking the Supreme Court to hear our case to resolve a dispute between the circuits,” said SAF Executive Director Adam Kraut. “The lower courts are not unanimous in their approach to the Second Amendment rights of 18-20-year-olds. It is important that the Court weigh in to confirm that 18-20-year-olds are part of ‘the People’ and the Second Amendment applies in full to those individuals.”
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The Minnesota law in question bars adults under 21 from obtaining permits to carry firearms in public, a restriction Kraut calls “patently unconstitutional.” SAF’s brief argues that the ban effectively strips young adults of their right to self-defense, a right upheld for this age group by a majority of federal courts.
“While we prevailed at the court of appeals, the Supreme Court needs to ensure all the lower courts reach the proper result,” Kraut added. “By taking this case, they can do just that.”
SAF founder and Executive Vice President Alan M. Gottlieb emphasized the historical context supporting their position.
“A clear majority of federal courts have already protected the Second Amendment rights of young adults,” he said. “As we note in our brief, we are not aware of any evidence of colonial or Founding-era laws restricting 18-to-20-year-olds from their right to keep and bear arms. Indeed, history is full of evidence that people in this age group were not prevented from keeping or carrying their own arms.”
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The case has evolved since its inception. Initially titled Worth v. Harrington, it was renamed Jacobson v. Worth following a change in Minnesota’s Department of Public Safety leadership. The Eighth Circuit’s ruling in July 2024 struck down the state’s age restriction as unconstitutional, prompting Minnesota Attorney General Keith Ellison to seek Supreme Court review.
SAF’s response brief, filed today, doubles down on the call for clarity, arguing that inconsistent circuit court decisions necessitate a unified standard.
As the Supreme Court considers whether to take up Jacobson v. Worth, the outcome could set a precedent for concealed carry laws affecting young adults across the country.
For now, the case remains stayed pending the justices’ decision, leaving Minnesota’s 18-20-year-olds unable to apply for carry permits. With both sides urging review, the stage is set for a potential landmark ruling on the scope of Second Amendment protections.
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