The Impact of the Supreme Court’s Bruen Decision on Gun Rights in Minnesota

The Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen significantly reshaped how courts evaluate firearm regulations across the United States. By replacing traditional balancing tests with a “history and tradition” standard, the ruling has prompted new challenges to state gun laws nationwide. Minnesota became one of the key states where the effects of Bruen quickly unfolded, particularly regarding age restrictions on handgun carry permits. Court rulings following Bruen have already expanded certain rights for young adults while leaving many existing regulations intact. This blog outlines how the Bruen decision changed the legal framework for gun regulations and how it directly impacted gun rights in Minnesota.

Key Takeaways

• The Supreme Court’s June 23, 2022, Bruen ruling fundamentally changed how courts evaluate gun regulations, requiring consistency with America’s historical tradition of firearm regulation rather than modern policy balancing.
• Applying Bruen’s framework, the 8th Circuit Court of Appeals struck down Minnesota’s age-21 minimum requirement for handgun carry permits, extending carry rights to law-abiding 18–20-year-olds.
• The US Supreme Court in 2025 declined to review Minnesota’s appeal, leaving the 8th Circuit decision intact and effectively final for the state.
• Most other Minnesota gun laws remain in force, including training requirements, background checks, and sensitive places restrictions.
• Bruen has sparked ongoing litigation that could further expand or clarify Second Amendment rights in Minnesota and across the nation.

How Bruen Reached Minnesota

The Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen stands as the most consequential Second Amendment ruling in more than a decade. Decided on June 23, 2022, it joined District of Columbia v. Heller (2008) and McDonald v. City of Chicago (2010) as the foundational trilogy defining the constitutional right to bear arms. While Heller established that the Second Amendment protects an individual’s right to keep handguns at home, and McDonald applied that protection to the states, Bruen extended these protections beyond the home, affirming that law-abiding citizens have a right to carry firearms in public for self-defense.

Bruen immediately triggered a wave of federal lawsuits across the country, and Minnesota was no exception. Gun rights groups filed challenges to discrete elements of Minnesota law, particularly the state’s requirement that individuals be 21 or older to obtain a permit to carry a pistol in public. Although Minnesota operates a “shall-issue” permitting system—unlike New York’s discretionary “may issue” regime that Bruen invalidated—the new legal standard invited fresh scrutiny of any categorical restrictions not clearly rooted in historical practice. This blog traces how Bruen changed the legal framework and directly led to Minnesota’s age-based carry restriction being struck down.

Background: NYSRPA v. Bruen and the New Second Amendment Test

New York State Rifle & Pistol Association Inc. v. Bruen arose as a challenge to New York’s public-carry licensing law, which required applicants to demonstrate “proper cause” or a special need for self-defense before obtaining a permit. The case reached the Supreme Court after the Second Circuit upheld New York’s framework under traditional means-end scrutiny.

• Invalidating “proper cause” requirements: The Court’s 6-3 majority, authored by Justice Clarence Thomas, held that New York’s discretionary licensing regime violated the Second Amendment. The ruling affirmed that ordinary, law-abiding citizens possess a constitutional right to carry a loaded handgun in public for self-defense, without needing to prove a special need beyond the general desire for protection.
• Rejecting means-end scrutiny: Bruen explicitly rejected the interest-balancing approach that lower courts had employed for years. Instead of weighing government interests against individual rights, courts must now apply a “text, history, and tradition” standard. Modern firearm regulation must be consistent with the nation’s historical tradition of firearm regulation to survive constitutional challenge.
• The new burden on government: Under Bruen, once a person’s conduct falls within the Second Amendment’s plain text—covering “the people” who hold individual rights under the Constitution—the government bears the burden of demonstrating that its restriction has a relevantly similar historical analogue from the Founding era (circa 1791) or Reconstruction period (ratification of the Fourteenth Amendment in 1868).
• Sensitive places doctrine: The majority acknowledged that laws prohibiting firearms in “sensitive places” like courthouses, polling places, schools, and legislative chambers have historical support and remain presumptively lawful. However, the Court cautioned against expansive definitions that would effectively gut the right to public carry.
• Concerns about uncertainty: Concurring and dissenting opinions criticized the heavy reliance on historical analogies. Justice Breyer’s dissent argued that the history-and-tradition test is subjective, unpredictable, and ignores modern societal changes like urban density and gun violence statistics. These concerns have proven prescient as lower courts have reached inconsistent results.

Bruen’s Immediate Legal Ripple Effects Nationwide

The Bruen decision opened the floodgates of litigation. By mid-2024, federal courts faced over 2,000 Second Amendment challenges—a dramatic increase that forced judges nationwide to become amateur historians in evaluating gun regulations.

Courts have grappled with challenges to assault weapons bans, magazine capacity limits, sensitive-places expansions, ghost gun serialization requirements, and various age restrictions. The results have been decidedly mixed:

Type of Regulation	Approximate Survival Rate
Carry laws generally	76% upheld
Age-based restrictions	35% upheld (65% struck down)
Domestic violence prohibitions	Mostly upheld
Assault weapons bans	Circuit split

For example, the Seventh Circuit upheld Illinois’ assault weapons ban by analogizing to historical traditions of militia regulation. Meanwhile, the Third and Eleventh Circuits invalidated age-21 carry limits similar to Minnesota’s, finding no founding-era tradition of categorically disarming people ages 18–20. Research from the Duke Center for Firearms Law has tracked these rulings, revealing that courts uphold challenged laws roughly 88% of the time in civil cases when they identify sufficient historical analogues—but age-based categorical bars have fared poorly. These nationwide developments set the stage for Minnesota’s own legal battles, particularly regarding who may lawfully carry firearms and under what conditions.

Minnesota’s Permit-to-Carry Framework Before Bruen

Minnesota has long operated a “shall-issue” permit-to-carry system under Minn. Stat. § 624.714. Unlike New York’s rejected “proper cause” framework, Minnesota law required sheriffs to issue permits to applicants who met objective statutory criteria—without demanding proof of a special need for self-defense.

The core features of this system included:

• Permits required for carrying handguns in public
• Background checks through the National Instant Criminal Background Check System (NICS)
• Completion of an 8-hour training course covering safe handling, storage, and legal use of force
• Fingerprint submission and application fees
• Issuance by county sheriffs, absent disqualifying factors

Critical disqualifiers included felony convictions, domestic violence misdemeanors, active domestic violence restraining orders, chemical dependency adjudications, and mental health commitments within five years.

However, Minnesota law imposed a 21-year minimum age for carry permits. This meant that young adults aged 18–20 could possess certain firearms (including long guns) and even serve in the military, but could not obtain permits to carry handguns in public.

Because Minnesota’s system did not involve the discretionary “proper cause” requirement struck down in Bruen, it initially appeared less vulnerable to challenge. But Bruen’s emphasis on historical tradition invited new scrutiny of any categorical bar not clearly rooted in founding-era practice—including the age restriction.

The Key Minnesota Case: Worth v. Jacobson and the Age-21 Carry Ban

The pivotal Minnesota case challenging the age restriction was Worth v. Jacobson, filed on June 7, 2021, in the U.S. District Court for the District of Minnesota. The lawsuit was brought by individual plaintiffs Kristin Worth, Austin Dye, and Axel Anderson—law-abiding 18–20-year-olds—alongside the Minnesota Gun Owners Caucus, Second Amendment Foundation, and Firearms Policy Coalition.

The plaintiffs’ arguments were straightforward under Bruen’s framework:

• 18–20-year-olds fall within “the people” protected by the Second Amendment
• The plain text of the Amendment makes no age-based distinction for adults
• Historical evidence shows 18 marked militia adulthood under the Militia Act of 1792
• No founding-era laws broadly disarmed this cohort
• Young adults participated in civic duties, including jury service and firearm possession

Minnesota defended its law with several arguments:

• 19th-century state laws raised carry ages to 21 amid urbanization
• English common-law restrictions applied to “infants” under 21
• FBI data showed 18–20-year-olds accounted for 20% of firearm arrests despite representing only 7% of the population
• The Bureau of Justice Statistics indicated that this age group commits 25% of violent crimes

The district court initially granted summary judgment for the plaintiffs on March 31, 2023, finding that Minnesota’s historical analogues were not “relevantly similar” to the challenged restriction. Colonial-era laws targeted minors under 14 or apprentices, not 18–20-year-olds who were legal adults with militia obligations. The court also rejected crime statistics as impermissible means-end balancing under Bruen.

The 8th Circuit’s Ruling: Expanding Carry Rights for Young Adults

In July 2024, the 8th Circuit Court of Appeals affirmed the lower court’s ruling, holding Minnesota’s ban on carry permits for 18–20-year-olds unconstitutional under the Second Amendment.

The appeals court’s central reasoning focused on Bruen’s requirements:

The Second Amendment’s plain text covers 18–20-year-old adults as part of “the people,” and Minnesota failed to identify a well-established historical tradition of categorically disarming this age group.

Key elements of the 8th Circuit’s analysis included:

• Text-based protection: The court found that 18–20-year-olds are unquestionably part of “the people” protected by the Second Amendment, just as they hold rights under the First and Fourth Amendments
• Rejection of modern data: The circuit court emphasized Bruen’s admonition against means-end balancing, dismissing reliance on modern crime statistics and generalized safety concerns
• Historical analogues lacking: Minnesota could not point to founding-era or Reconstruction-period laws that categorically prohibited otherwise law-abiding 18–20-year-olds from carrying firearms for self-defense
• Alignment with sister circuits: The 8th Circuit’s decision aligned with similar rulings from the Fifth and Eleventh Circuits, striking down comparable age restrictions

As a result of this ruling, law-abiding 18–20-year-olds in Minnesota who meet all other statutory criteria—training, background checks, and absence of disqualifying factors—must be eligible to receive a permit to carry a handgun in public.

The decision also binds other states within the 8th Circuit that maintained similar restrictions, including Arkansas, Iowa, Missouri, Nebraska, North Dakota, and South Dakota.

The Supreme Court’s Refusal to Revive Minnesota’s Age Restriction

After the 8th Circuit’s decision, Minnesota petitioned the US Supreme Court for review, asking the justices to reinstate the age-21 carry requirement. The state argued that irreconcilable circuit splits existed on 18–20-year-old carry rights and that public safety risks justified its policy. Twenty-two other states and gun control organizations, including the Giffords Law Center, filed amicus briefs supporting Minnesota’s position.

On March 10, 2025, the Supreme Court denied Minnesota’s petition for certiorari without opinion or noted dissent.

This denial carries important practical implications:

• A denial of certiorari is not a ruling on the merits
• However, it leaves the 8th Circuit’s decision final and controlling within its jurisdiction
• Minnesota must administer its permitting system without the age-21 ceiling
• The Court’s silence provides no additional guidance on age-based restrictions

Notably, the Supreme Court around this same period also declined to intervene in other post-Bruen cases testing sensitive-places rules and campus gun restrictions, including a University of Michigan case. This pattern suggests the Court’s restraint in micromanaging lower courts as Bruen’s implementation continues—though only about 1-2% of certiorari petitions are granted in any given term.

What Has Changed for Minnesota Gun Owners After Bruen

The practical changes flowing from Bruen and subsequent rulings are now in effect for Minnesota residents. Here is what has changed—and what has not:

Changes now in effect:

• 18–20-year-old Minnesotans who are otherwise eligible can now apply for and receive permits to carry handguns in public
• The Minnesota Department of Public Safety updated permit application forms by late 2024 to reflect this change
• County sheriffs must process applications from young adults without age-based denial

What remains the same:

Element	Status
Shall-issue framework	Unchanged
Background check requirement	Unchanged
8-hour training course	Unchanged
Application procedures	Unchanged
Felony prohibition	Unchanged
Domestic violence prohibitor	Unchanged
Mental health commitment bar	Unchanged
Sensitive places restrictions	Unchanged

Minnesota’s prohibitions on firearm possession by felons, certain domestic violence offenders, and other disqualified persons continue to operate, though some individuals may qualify under specific eligibility criteria for restoring gun rights. The Supreme Court has consistently recognized that Second Amendment rights are not unlimited—categories of prohibited persons with historical analogues remain valid.

For people affected by prior convictions or disqualifying circumstances, the legal path forward is often highly fact-specific. Questions about eligibility, court procedure, and available remedies can become just as important as the constitutional issues discussed in Bruen, which is why understanding how to restore your gun rights in Minnesota can be an important next step for individuals seeking to lawfully regain their firearm rights. “Sensitive place” rules also remain in effect. Prohibitions in courthouses, schools (K-12 and colleges), jails, legislative chambers, and secured airport areas continue under Minnesota law. Though Bruen has prompted debates over whether additional locations could be added or challenged, existing prohibitions stand.

The state’s approximately 450,000 active permit holders (as of 2023 data) now include eligible 18–20-year-olds, though sheriffs have reported increased application volumes and some processing backlogs.

Ongoing Litigation and Unresolved Questions in Minnesota

Worth v. Jacobson represents only one piece of Minnesota’s evolving Second Amendment landscape. Bruen created a long-term shift that continues to generate litigation.

Gun rights groups are actively reviewing remaining Minnesota statutes for potential challenges. The Minnesota Gun Owners Caucus, Second Amendment Foundation, and national organizations like the Firearms Policy Coalition have signaled interest in testing additional restrictions.

Areas that may see future litigation:

• Expanded definitions of “sensitive places” beyond traditional locations
• Restrictions connected to public transit or university campuses
• Rules on certain firearm types or magazine capacities
• Any remaining age-based or categorical bans
• Red-flag law provisions under Minn. Stat. § 624.712

Lower courts in Minnesota must now apply Bruen’s historical-tradition test in these future cases. This requires examining analogues from the 18th and 19th centuries rather than relying on modern policy arguments alone. Expert analysis from the Duke Center suggests that governments prevail in about 70% of post-Bruen appellate cases when they present robust historical briefing—but the 8th Circuit has shown skepticism toward “modern sensibilities” arguments.

At the same time, not every firearm-rights issue in Minnesota depends on a new constitutional challenge. In many cases, the more immediate concern involves whether an individual can pursue relief through existing state procedures, judicial restoration, or other recognized avenues. For readers trying to understand those practical options, restoring firearm eligibility in Minnesota state relief pathways and timelines provides useful context on how these processes may work.

Appellate decisions from other circuits—both upholding and striking down state laws—could indirectly influence how a federal judge in Minnesota interprets Bruen, especially where historical evidence is contested. The Giffords Law Center tracks these developments nationally, estimating that 20-30% more gun laws could face invalidation under Bruen’s standard.

How Bruen Affects Lawmakers, Law Enforcement, and Citizens

Bruen has reshaped the landscape for everyone involved in Minnesota’s gun regulations—from legislators drafting new laws to citizens exercising their rights.

For lawmakers:

• New gun regulations must be drafted with demonstrable historical support
• Legislative staff now require constitutional analysis and historical research before proposing restrictions
• Reports indicate that developing Bruen-compliant legislation can cost $50,000 or more per bill in research and expert consultation
• 2024 session proposals for expanded “sensitive place” designations (including stadiums and hospitals) stalled over concerns about surviving a constitutional challenge

For law enforcement:

• County sheriffs must update policies, training, and application forms
• 18–20-year-old applicants must be processed in compliance with the post-Worth legal framework
• Sheriffs have reported a 15% increase in applications from young adults
• No additional discretion may be exercised beyond objective statutory criteria

For citizens:

• Those wishing to exercise carry rights must still comply with permitting procedures
• Training requirements and background checks remain mandatory
• The law remains in flux as new challenges are filed and decided
• Monitoring official state and county guidance is essential

Minnesota residents should be aware that practical implementation—including application backlogs, training availability, and local interpretations—can evolve even after formal legal rulings take effect. The Minnesota Department of Public Safety website (publicsafety.state.mn.us) provides current information on permit requirements and procedures.

Read More: How Will I Know If My Gun Rights Have Been Restored?

The Long-Term Impact of Bruen on Minnesota Gun Rights

The Supreme Court’s Bruen decision altered the fundamental test courts use to evaluate gun restrictions, and Minnesota’s age-21 carry restriction became one of its earliest casualties. The trajectory is clear: Bruen changed the standard, the 8th Circuit applied that standard to strike down Minnesota’s age-based bar, and the Supreme Court’s refusal to intervene cemented that outcome.

While the scope of permissible regulation has narrowed in some respects—particularly for categorical restrictions on law-abiding young adults—most of Minnesota’s core gun-safety framework remains intact. Background checks, training requirements, and prohibitions on firearm possession by felons and domestic violence offenders continue to operate. The state’s sensitive place restrictions also endure, with historical analogues supporting bans in schools, courthouses, and similar locations.

Minnesota now participates in a broader national experiment applying Bruen’s history-and-tradition test. This framework may produce further changes as courts decide new Second Amendment cases involving everything from magazine capacities to campus carry rules. The past year has demonstrated that outcomes depend heavily on the quality of historical evidence presented—and the 8th Circuit’s approach suggests further expansion of gun rights is possible within this jurisdiction.

The balance between public safety and individual amendment rights will continue to be worked out through ongoing litigation, legislative adaptation, and eventual Supreme Court guidance. With over 150,000 newly eligible 18–20-year-olds and active gun rights organizations pursuing additional challenges, Minnesota is likely to remain a focal point for age-related and carry-rights questions in the years ahead, illustrating why gun rights are becoming a state-level issue again under the Bruen and Rahimi framework.

Protecting Your Rights in a Changing Legal Landscape

The Supreme Court’s Bruen decision has reshaped the legal framework surrounding firearm regulations across the United States, including Minnesota. By requiring courts to evaluate gun laws based on historical tradition rather than modern policy balancing, the ruling has already influenced important legal decisions—such as expanding carry rights for law-abiding young adults in Minnesota. While many regulations remain in place, the interpretation of the Second Amendment continues to evolve through court decisions and legislative responses. For individuals dealing with firearm restrictions, permit denials, or past convictions that affect their rights, speaking with a knowledgeable gun rights restoration lawyer in Minnesota helps clarify the legal options available.

If you are facing firearm-related legal issues or criminal charges, Lynne Torgerson, Criminal Defense Attorney, provides experienced legal representation throughout Minnesota. With more than 29 years of experience handling criminal defense and Second Amendment cases, Lynne Torgerson has successfully represented clients seeking restoration of firearm rights and defense against serious criminal charges. If you need help restoring your firearm rights or defending your record and future, explore the firm’s services, including gun rights restoration lawyer, sex crimes lawyer, assault lawyer, and criminal defense lawyer. Contact Lynne Torgerson today to schedule a consultation and receive dedicated legal guidance tailored to your situation.

Frequently Asked Questions

Can 18–20-year-olds now legally carry handguns in public in Minnesota?

Yes. Following the 8th Circuit’s decision in Worth v. Jacobson and the Supreme Court’s denial of Minnesota’s petition for review, law-abiding 18–20-year-olds who meet all other statutory requirements can obtain permits to carry handguns in public. These requirements include completing the mandatory training course, passing a background check, and having no disqualifying record, such as felony convictions or domestic violence misdemeanors. There is no automatic right to carry without a permit—young adults must go through the same application process as older adults.

Did Bruen or the Minnesota cases eliminate the need for a permit to carry?

No. Minnesota continues to operate under a permit-to-carry system, and nothing in Bruen required states to adopt “permitless carry” or “constitutional carry” frameworks. The Supreme Court specifically noted that shall-issue permitting regimes with objective criteria like background checks, training, and fingerprints are unlikely to burden Second Amendment rights significantly. What changed in Minnesota is who can qualify for a permit—the pool of eligible applicants expanded to include 18–20-year-olds, not whether a permit is necessary to lawfully carry.

Are Minnesota’s restrictions on guns in schools, courthouses, and other sensitive places still valid?

Yes. These “sensitive place” restrictions remain in effect under Minnesota law. Bruen specifically endorsed the constitutionality of prohibitions in certain sensitive locations that have strong historical analogues—including schools, courthouses, polling places, and legislative buildings. Future litigation might test the boundaries of what qualifies as a sensitive place under the historical-tradition test, but existing prohibitions in K–12 schools, courthouses, jails, and similar locations remain enforceable.

Does Bruen affect Minnesota’s ability to regulate assault weapons or high-capacity magazines?

Bruen did not directly address assault weapons or magazine capacity limits, and Minnesota’s current regulations in these areas have not been definitively resolved under the Bruen standard. Cases from other states—with courts reaching split decisions—are moving through the federal system and may influence how any future Minnesota challenges are analyzed. National tracking suggests roughly 50/50 splits on magazine restrictions, indicating significant uncertainty in this area of firearms law.