Federal Judge Rules Missouri County’s Under-21 Handgun Ban Violated the Second Amendment

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KANSAS CITY, MO — A federal judge has ruled that Jackson County’s short-lived ban on handgun purchases by adults under 21 violated the Second Amendment.

In an order dated June 24, U.S. District Judge Beth Phillips granted partial summary judgment to plaintiff Leonard Wilson Jr., finding that Section 1 of the county’s former gun ordinance ran afoul of the Constitution. Wilson was 18 when the suit was filed. He wanted to buy a handgun and ammunition from his uncle, who was willing to sell, and the two had already agreed on a price.

The court did not need a long historical analysis to get there. Judge Phillips held that the outcome was dictated by the Eighth Circuit’s 2024 decision in Worth v. Jacobson, which struck down a Minnesota law barring 18-to-20-year-olds from carrying firearms. Adults in that age range, the appeals court held, are part of “the people” the Second Amendment protects.

Phillips also rejected the county’s claim that the right to buy a firearm is somehow separate from the right to own one. A person cannot possess a firearm without first acquiring one, she reasoned, so a government that cannot ban possession cannot ban the purchase either. She pointed to the Fifth Circuit’s ruling in Reese v. ATF, which held that the right to keep and bear arms “surely implies the right to purchase them.”

The ordinance at the center of the case has a telling backstory. Jackson County passed Ordinance No. 5865 in November 2024, overriding a veto from County Executive Frank White Jr. Section 1 banned anyone under 21 from buying a handgun or handgun ammunition. Section 3 barred adults 18 to 20 from possessing a “semiautomatic assault rifle,” a term the ordinance never bothered to define.

The sponsor, First District Legislator Manny Abarca, was candid about the plan. According to the complaint, Abarca said the legislature wrote the ordinance knowing it would be challenged, “hoping for a court battle.” White had warned in his veto that the measure was unlawful and would stick taxpayers with the bill for defending a law unlikely to survive.

Then-Attorney General Andrew Bailey sued in June 2025, joined by Wilson, Gun Owners of America, and Gun Owners Foundation. Bailey called the right to keep and bear arms inalienable when he announced the action. He has since left state office to serve as co-deputy director of the FBI, and Catherine Hanaway now leads the Missouri Attorney General’s Office.

The county did not wait for a courtroom defeat. About three and a half weeks after the plaintiffs moved for a preliminary injunction, Jackson County repealed Ordinance 5865 and replaced it with a measure that applies only to minors. Because Wilson was already an adult, the case narrowed to his claim for nominal damages.

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That timing shaped what the court could decide. Phillips granted Wilson summary judgment only on Section 1, the handgun purchase ban. She deferred ruling on Section 3, the so-called assault rifle provision, finding Wilson likely lacked standing because he never bought such a rifle and described only a “some day” intention to do so. She also questioned whether the State of Missouri still has standing now that only Wilson’s damages claim remains.

The judge gave Wilson and the State 21 days to answer those questions, and she vacated the pretrial conference and bench trial that had been set for this summer.

Even with those issues open, the core holding is clear. A federal court has now added Jackson County’s ordinance to the growing pile of age-based gun restrictions falling under Bruen and Worth. Courts in the Fifth, Eighth, and Third Circuits have all recognized that 18-to-20-year-old adults do not surrender their Second Amendment rights at some arbitrary age line.

I will keep tracking this case as Wilson and the State respond to the court’s standing questions and the remaining claims are resolved.