Federal Judge Rules Jackson County’s Under-21 Handgun Ban Violated the Second Amendment
A federal judge from the United States District Court for the Western District of Missouri, Western Division, has ruled that an ordinance banning anyone under 21 from buying handguns or handgun ammunition was unconstitutional.
In November 2024, Jackson County passed Ordinance No. 5865. Section 1 of the ordinance prohibited the sale or transfer of handguns and handgun ammunition to anyone under 21 (and purchase by those under 21). Section 3 prohibited individuals aged 18–20 from possessing semiautomatic assault rifles (with limited exceptions).
Leonard Wilson, Jr. (age 18 at filing), Gun Owners of America (GOA), Gun Owners Foundation (GOF), and the State of Missouri sued Jackson County, the County Sheriff, and the County Prosecutor in Leonard Wilson, Jr. et al. v. Jackson County, Missouri, et al. Wilson wanted to buy a handgun and ammunition from his uncle, but was blocked by the ordinance.
Shortly after the suit was filed in June 2025, the County repealed the Prior Ordinance and replaced it with a narrower Current Ordinance (Ordinance No. 6002) that only applies to minors under 18.
On February 10, 2026, the judge in the case dismissed GOF from the case for lack of standing. GOA was dismissed because the judge found the injunctive relief claims moot. He also dismissed Count III (state preemption) on supplemental jurisdiction grounds. The February 10 ruling left Wilson and the State with only claims for nominal damages on Counts I (Second Amendment) and II (vagueness).
Young Adults Are Protected by the Second Amendment
The court granted in part and deferred in part the motion on June 24, 2026. The Court ruled that Section 1 of the Prior Ordinance violated Wilson’s Second Amendment rights. The judge relied heavily on the Eighth Circuit’s decision in Worth v. Jacobson, 108 F.4th 677 (8th Cir. 2024), which struck down a Minnesota law restricting 18–20-year-olds from obtaining permits to openly carry firearms. He ruled that people 18 and older are protected by the Second Amendment.
The judge found that age-based restrictions like this lack historical tradition under the Bruen framework. The right to keep and bear arms implies the right to acquire or purchase firearms; a ban on purchase is an indirect prohibition on possession.
The Court was not convinced that Wilson had standing to challenge the assault weapon provision of the ordinance and will address jurisdiction further.
The case is limited to nominal damages (symbolic compensation) for the constitutional violation of the repealed ordinance. The Defendants’ arguments, which attempted to distinguish Bruen and Worth (e.g., self-defense vs. range use, purchase vs. possession), were rejected by the judge. They tried to argue “common use for self-defense,” but the judge pushed back, pointing out that the United States Supreme Court said common use applies for “lawful purposes” and not just “self-defense.”
The judge wrote: “Defendants do not conduct their own Bruen analysis. They do not even mention Worth. Instead, they attempt to distinguish Bruen because of its discussion about the Second Amendment’s relation to the right to self-defense, whereas Wilson wants a handgun so he can shoot it at a firearms range. (Doc. 48, pp. 9-11.) However, nothing in Bruen, or any other case, holds that the Second Amendment applies only to people who want a firearm for self-defense.”
Even though the ordinance was repealed, this is still a victory for the Second Amendment. It shows that localities cannot pass an unconstitutional ordinance and then repeal it once sued to dodge responsibility.
About John Crump
Mr. Crump is an NRA instructor and a constitutional activist. John has written about firearms, interviewed people from all walks of life, and on the Constitution. John lives in Northern Virginia with his wife and sons. Follow him on X at @right2bear or at www.crumpy.com.
