Both the federal government and state governments may restrict young adults’ ability to obtain, possess, or carry firearms, a federal judge has ruled.

US District Judge Sarala Nagala on Thursday upheld the federal ban on federally licensed firearms dealers selling handguns to adults under the age of 21. She likewise upheld Connecticut’s broader state restrictions, which also collectively bar the same age group from being able to possess or carry handguns. Nagala did so after determining that modern weapons restrictions for 18-to-20-year-olds are sufficiently rooted in history.

“Having considered all the admissible testimony of the witnesses and all the admissible documentary evidence, the Court finds that the State and Federal Handgun Restrictions do not violate Plaintiffs’ Second Amendment or Fourteenth Amendment rights, as they are consistent with this Nation’s history and tradition of firearms regulation,” Judge Nagala wrote in Succow v. Blanche.

The ruling marks the latest foray by a court into one of the most hotly contested fields of Second Amendment law, namely whether gun-control restrictions on those under 21 can survive constitutional scrutiny. The federal courts of appeals are currently split three to three on the answer to that question, at least in certain contexts, and the US Supreme Court has thus far declined to resolve the open circuit split. Further rulings like the one delivered Thursday could add pressure on the justices to eventually weigh in.

The case arose after plaintiffs Zachary Succow and Samuel Towne, two 19-year-old Connecticut residents, partnered with the Connecticut Citizens Defense League and Second Amendment Foundation to challenge the state and federal barriers preventing them from purchasing and possessing handguns for self-defense. The suit was first filed in February 2025.

To adjudicate their claims, Judge Nagala held a two-day bench trial featuring testimony from expert witnesses regarding the legal status of 18-to-20-year-olds at the Founding and throughout American history.

In her 76-page ruling, Nagala said she was persuaded by testimony explaining that 18-to-20-year-olds were considered minors at the time of the Founding and often lacked contract rights to purchase certain commercial goods. She said that status alone was enough to justify the modern federal restriction on commercial handgun sales to young adults.

“The Federal Framework’s prohibition on the commercial sale and delivery of handguns to individuals between the ages of eighteen and twenty is consistent with the historical inability at the Founding for minors under the age of twenty-one to enter into contracts for the sale of commercial goods, given that minors were deemed to lack appropriate judgment and discretion,” Nagala, a Joe Biden appointee, wrote. “To be sure, Founding era infancy doctrine prohibiting minors from contracting for non-essential goods is not a ‘dead ringer’ for the Federal Framework. But that is of no matter, as courts need not search in vain for such a ‘historical twin,’ when there exists a sufficient analogue that ‘comport[s] with the principles underlying the Second Amendment.'”

However, Nagala also held that the Founding-era “infancy doctrine” alone was insufficient to uphold Connecticut’s restrictions, which also prohibit those under 21 from simply possessing or carrying a handgun.

“While it is clear that, at the Founding, certain subsets of minors were prohibited from possessing and carrying handguns in certain instances (such as in the university context) and in others were expected to do so (such as in the militia context), there are no laws or restrictions that demonstrate a general societal restriction nor a general societal acceptance on minors possessing or carrying arms,” she wrote.

Instead, Nagala said that late-19th-century history was necessary to justify Connecticut’s young-adult handgun bans.

“In sum, several states’ laws during the Reconstruction era operated as historical analogues for the Connecticut Framework’s prohibition on the possession and carrying of handguns by individuals under the age of twenty-one,” she concluded. “These regulations share the same how and why as the Connecticut Framework. While these laws vary at times in their breadth, or the exact penalty imposed for violation, these laws are sufficiently close in method to the current Connecticut Framework, supporting its constitutionality.”

Connecticut officials celebrated the ruling.

“This is a major victory for commonsense gun safety and for Connecticut families,” Attorney General William Tong (D.) said. “The court rejected another radical challenge to dismantle Connecticut’s gun safety laws and affirmed what we’ve argued from the start. These age restrictions are constitutional and they save lives.”

The plaintiffs’ attorneys, meanwhile, expressed disappointment at the ruling and said they were weighing an appeal.

“The district court found no Founding Era support for the laws that stripped young adults of their constitutional rights,” they said in a joint statement to CT Insider. “That means, under US Supreme Court precedent, the court should have ruled for the plaintiffs. At this point, we are evaluating all options to restore the plaintiffs’ rights, including at the US Supreme Court if necessary.”