federal appellate circuits applying the Bruen historical standard
FLORIDA LAW ENACTED
2018
Marjory Stoneman Douglas High School Public Safety Act signed
MINIMUM AGE STRUCK DOWN
21
Florida's concealed carry age floor ruled unconstitutional
STATES IN 11th CIRCUIT
3
Florida, Georgia, and Alabama covered by this ruling
KEY RULINGS & EVENTS — 2008 TO 2026
POST-BRUEN RULINGS BY YEAR
STRUCK
UPHELD
PENDING
CASE TIMELINE
2008-06-26landmarkSupreme Court
District of Columbia v. Heller
Supreme Court rules the Second Amendment protects an individual right to keep and bear arms, unconnected to militia service. The opinion left open the question of what standard lower courts should apply to other gun regulations, leading circuit courts to develop a two-part means-ends balancing test in subsequent years.
In the wake of the Marjory Stoneman Douglas High School massacre, Florida raises minimum age for rifle and shotgun purchases to 21 and restricts concealed carry licenses to adults 21 and older.
Supreme Court strikes down New York's proper-cause requirement for concealed carry permits and replaces the two-part means-ends balancing test with a purely historical analysis: a firearms regulation is constitutional only if consistent with the nation's historical tradition at the Founding or Reconstruction.
11th Circuit Upholds Florida Age Restriction (Initial Panel)
An 11th Circuit panel initially upholds Florida's 21-and-older concealed carry restriction, finding some historical support for age-based firearms regulations.
The 4th Circuit strikes down a federal prohibition on handgun sales to adults under 21, applying the Bruen historical standard and finding no Founding-era tradition of disarming 18-to-20-year-olds.
Supreme Court upholds the federal domestic violence firearms prohibition, clarifying that Bruen does not require a 'historical twin' but rather a 'relevantly similar' historical analogue — providing some guidance on how broadly to apply the historical test.
The 8th Circuit rules that Iowa's concealed carry age restriction for adults 18–20 cannot survive the Bruen historical test, deepening the circuit split on age-based gun restrictions.
11th Circuit Strikes Florida Concealed Carry Age Restriction
On rehearing after intervening Supreme Court guidance, the 11th Circuit reverses its prior position and strikes down Florida's ban on concealed carry for adults 18–20, finding it inconsistent with the Second Amendment's text and the nation's historical tradition as required by Bruen.