The Third Circuit Court of Appeals upheld its previous decision on Tuesday which found Pennsylvania statutes preventing “18-to-20-year-olds from carrying firearms outside their homes during a state of emergency” unconstitutional.

Pennsylvania statutes 6106, 6107, and 6109 have the combined effect of “preventing most 18-to-20-year-old adult Pennsylvanians from carrying firearms.” The Appellants, Madison Lara, Sophia Knepley, and Logan Miller, brought the action against the Commissioner of the Pennsylvania State Police on Second Amendment grounds, arguing they should be able to carry firearms outside their homes “for lawful purposes, including self-defense.”

The court began its analysis with a discussion of several leading decisions regarding gun ownership and the Second Amendment. In District of Columbia v Heller (Heller), the Supreme Court held both the Second and Fourteenth Amendments enshrine the “right to possess a handgun at home for self-defense.” The court then explained that in New York State Rifle & Pistol Ass’n, Inc. v. Bruen (Bruen), the Supreme Court clarified the standard of review is not a “means-end scrutiny” and instead introduced a new two-step approach to determining the constitutional validity of firearm regulation. The Supreme Court applied the approach articulated in Bruen in United States v Rahimi (Rahimi).

One of the commissioner’s arguments included the position that youth in the 18-to-20-year-old age range do not fall in the scope of protection afforded by the Second Amendment. However, the court disagreed, finding the Supreme Court’s decision in Rahimi “construed the term ‘the people'” in the Second Amendment “to cast a wide net.”

Previously, the appellants requested a preliminary injunction while the commissioner brought a motion to dismiss the case. The district court granted the motion, citing the “‘broad consensus’ of decisions from other federal courts ‘that restrictions on firearm ownership, possession, and use for people younger than 21 fall within” regulations allowed by the Supreme Court decision in Heller. The appellants appealed, and the appeals court reversed the district court decision. The commissioner petitioned the Supreme Court for a writ of certiorari. The Supreme Court granted the certiorari writ, remanding the case to the appeals court for consideration in light of Rahimi.

Ultimately, the appeals court found that its prior analysis finding the law unconstitutional reflected these precedents, including Rahimi and Bruen.