In layman’s terms: The U.S. Court of Appeals for the Eleventh Circuit used flawed and twisted logic to uphold Florida’s ban on firearm sales to adults under 21 years of age.
In a decision that defies common sense and logic, the U.S. Court of Appeals for the Eleventh Circuit has upheld Florida’s prohibition on firearm purchases by individuals under 21 years of age.
(Similar bans have recently been found unconstitutional in Pennsylvania and Louisiana.)
In an 8-4, 169-page decision penned by Chief Judge Pryor, the en banc ruling in National Rifle Association v. Bondi, issued on March 14, 2025, affirms the district court’s ruling. Two separate dissenting opinions were written with four different judges joining.
Case Overview
The case, National Rifle Association and Colton Campbell v. Commissioner, Florida Department of Law Enforcement, stemmed from Florida’s Marjory Stoneman Douglas High School Public Safety Act, itself a response to the state’s response to the 2018 Parkland school shooting. The law, Fla. Stat. § 790.065(13), bans those under 21 from buying firearms, making violations a third-degree felony, though it allows exceptions for peace officers, correctional officers, and military personnel.
The NRA, joined by an individual plaintiff, sued, arguing the law violated their Second Amendment and Fourteenth Amendment rights. The U.S. District Court for the Northern District of Florida granted summary judgment for the state, prompting an appeal.
Initially argued before a panel, the case was reheard en banc after the Supreme Court’s Bruen decision (2022), which requires gun laws to match historical regulatory traditions, and Rahimi (2024), which upheld restrictions on dangerous individuals. The Eleventh Circuit, led by Chief Judge William Pryor, considered the appeal with a full bench of 11 active judges.
Court’s Decision
This case, as with many others addressing gun restrictions, is answered by a court that consistently uses a tragedy under the color of ‘public safety’ to push gun restrictions.
Hannah Hill, Vice President of NAGR’s legal arm, wryly observed, “A bizarre fact of the post-Bruen era is that many courts begin rabidly anti-gun opinions by correctly explaining the required Bruen analysis, only to make a complete hash of it when they actually conduct said analysis.”
The decision follows this pattern, skirting its way around Bruen in spectacularly colorful fashion.
The court begins with perhaps the only correct application of Bruen in the entire opinion:
To determine whether the Florida law is consistent with our regulatory tradition, we must first decide what tradition is relevant to that inquiry. For purposes of this appeal, the Founding era is the primary period against which we compare the Florida law.\”
In its defense of the anti-gun restrictions, the court leans heavily on contract law, asserting,
Among the many legal disabilities that ‘secured [minors] from hurting themselves by their own improvident acts,’ …minors generally lacked the capacity to contract… and to purchase goods on account…
As for what, or who a minor is, the Court asserts, “At the Founding, a person was an ‘infant’ or a ‘minor’ in the eyes of the law until age 21.”
Stretching the idea, the court writes, “The purchase of goods, including firearms, required the ability to contract because people often bought goods on credit.” Ipso facto, a minor couldn’t have purchased a firearm!
Another bizarre defense of the restriction surrounds militia laws with the court writing,
…members of Congress recognized that individuals between the ages of 18 and 21 would need their parents to provide them weapons to comply with the [militia] Act.
And so, to complete the thought that proves their anti-gun position, the court posits that numerous states,
…implicitly required parents to supply minors with firearms because those states held parents liable for minors’ fines related to militia service, including the failure to obtain a firearm.
The lengthy decision goes on to discuss university bans and other irrelevant minutia. As with many decisions, they require length and verbosity to undermine simple concepts that stand today: no other rights enumerated in the Bill of Rights are denied to adults.
In his dissent, Judge Brasher argues that 18- to 21-year-olds, as part of “the people,” have a Second Amendment right to buy firearms, unburdened by Founding-era analogues. “There were no Founding-era laws prohibiting young adults from purchasing any firearm at all,” he asserted, highlighting militia duties as evidence of expected gun ownership.
