Pennsylvania Won't Let 18-to-20-Year-Olds Even Apply for a Carry Permit
Pennsylvania bars adults under 21 from applying for a carry license at all, and the Firearms Policy Coalition and the NRA are suing the Commonwealth over it. FPC filed Maines v. Bethel in the U.S. District Court for the Eastern District of Pennsylvania. The suit challenges the state's ban on lawful carry in most public places by adults aged 18 to 20. A member whose self-defense rights the state is denying joins FPC and the NRA as a plaintiff. The filing lands on a simple contradiction. A legal adult can buy a rifle from a dealer in Pennsylvania at 18, yet cannot carry a handgun to the grocery store or to work without facing prosecution.
Key Details
The complaint centers on how Pennsylvania's carry framework interacts with age.
- Pennsylvania generally requires a license to carry a concealed firearm, to carry in a vehicle, or to carry in public in Philadelphia.
- The state categorically prohibits anyone under 21 from applying for that license.
- Open carry without a license is allowed in some circumstances, but not for 18-to-20-year-olds in vehicles or on Philadelphia streets.
- Violations can bring felony charges and prison time, according to the plaintiffs.
- FPC President Brandon Combs argued that Pennsylvania treats these adults as second-class citizens. He pointed to their ability to enlist in the military, vote, marry, and sign binding contracts.
- The case extends FPC's earlier win in Lara v. Paris, decided by the U.S. Court of Appeals for the Third Circuit.
- In Lara, the Third Circuit held that 18-to-20-year-olds are protected by the Second Amendment. It rejected Pennsylvania's limits on their open carry during declared emergencies.
- After the Supreme Court sent Lara back for reconsideration, the Third Circuit reaffirmed its decision in January 2025.
The FPC and NRA argue that Lara is binding precedent, yet the Commonwealth still enforces the separate licensing bar. That bar, not the emergency open carry rule, is the target of this suit.
Background
Federal law and Pennsylvania law treat young adults differently, and that difference creates the problem. Under 18 U.S.C. § 922(b)(1), licensed dealers cannot sell handguns to anyone under 21. Federal law does not bar those under 21 from possessing handguns, and it sets no federal age floor for carrying them. That leaves states to decide carry rules. Pennsylvania chose to close the licensing door entirely for this age group.
The Supreme Court's 2022 decision in New York State Rifle & Pistol Association v. Bruen changed the analysis. Courts now ask whether the Second Amendment's plain text covers the conduct. If it does, the government must justify its restriction by pointing to historical analogues. The Third Circuit applied that framework in Lara. It found the 18-to-20 age group protected by the text, which set up the current challenge. The new suit asks whether a categorical licensing ban survives the same test that the emergency rule failed.
Why It Matters for Gun Owners
The direct victims of this law are Pennsylvania residents aged 18 to 20. Many already hold a valid firearms ownership record, serve in the military, or work in jobs that require commuting. They can own a handgun and still cannot carry it legally in the most common places a person drives to every day. A trip to work by car can turn into a felony exposure under this framework.
The impact reaches beyond the plaintiffs. Parents, first-time owners, and young hunters in the state face the same confusion. Dealers and instructors who train 18-to-20-year-olds will hear the questions first. Anyone in that age bracket should assume that open carry is not a substitute for a license in a vehicle or in Philadelphia. Know the statute before you carry. Keep your purchase records and any ownership documentation within reach. If you have questions about a specific situation, talk to a Pennsylvania firearms attorney before you leave the house with a gun. Watch the Eastern District docket for early rulings, because a preliminary injunction could change the rules quickly.
DownRange Analysis
This is a strong case under the Bruen framework, and the state's position is weak. The Third Circuit has already found 18-to-20-year-olds protected by the text of the Second Amendment. Pennsylvania now has to show that a total licensing bar matches a historical tradition of restricting carry by age. That burden is heavy. Most historical regulation of carry focused on specific conduct, such as carrying in sensitive places or carrying with intent to terrorize. A blanket age ban on applying for a license does not fit that pattern.
The market impact will show up in training and holster sales within the state. Young adults who can buy a pistol from a dealer but cannot carry it have little reason to take a defensive course. A court win would open that demand, and instructors in Pennsylvania should prepare for it. For now, the practical advice is simple. If you are under 21 in Pennsylvania, do not assume your rights match those of adults over 21. Verify the law, keep your paperwork, and follow the case as it moves forward.
