A federal court on Monday upheld Hawaii’s law prohibiting citizens under 21 years old from purchasing firearms and ammunition.
The U.S. District Court for the District of Hawaii shot down a challenge to the law by applying the Supreme Court’s ruling in New York Rifle & Pistol Association v. Bruen. The ruling mandates that any gun control law must remain “consistent with the principles that underpin our regulatory tradition.” This means there must be a law passed during the Founding era that is similar to those in effect today.
The court concluded that the state met this burden and denied the plaintiffs' lawsuit. The state argued that under early American common law, the infancy doctrine barred individuals younger than 21 from executing binding contracts, which applied to the purchase of firearms.
As part of SAF’s strategic objective of restoring the full breadth of gun rights to ALL Americans, late last evening we filed our Motion for Summary Judgment in Pinales v Lopez, our lawsuit challenging Hawaii’s restrictions on the Second Amendment rights of adults under 21. You… pic.twitter.com/E5nmJ6s4Ak
— SAF (@2AFDN) October 2, 2025
The judges examined late-19th century state statutes that were passed in response to industrialization and the advent of deadlier handgun technologies. These laws restricted gun sales, gifts, and loans to minors.
Federal Judge Keeps Hawaii's Under-21 Gun Ban in Placehttps://t.co/aFUg61xvlG
— Bearing Arms (@BearingArmsCom) February 10, 2025
“The court thus concludes that the founding era’s practical prohibition on acquisition, coupled with the 19th century’s explicit prohibitions, reveal a principle of restricting firearm acquisition for people under 21,” Judge Jill Otake wrote. “Hawaii’s current age restriction falls within that tradition.”
She also argued that just because 18-year-olds are considered adults, states still bar them from buying other products like alcohol and tobacco.
Hawaii's age-21 gun law survives Second Amendment challenge @JeremyYurow https://t.co/aKo1Rk6GVW
— Courthouse News (@CourthouseNews) September 1, 2026
The original lawsuit maintained that individuals between the ages of 18 and 20 should be considered eligible citizens with rights that the states cannot infringe on. The plaintiffs contended that the statutes have “denied, and will continue to deny, millions of responsible, peaceable, law-abiding adults under the age of 21” and “their fundamental, individual right to keep and bear arms secured under the Second and Fourteenth Amendments of the U.S. Constitution."
Other circuit courts, such as the Fifth Circuit, have ruled against similar age restrictions. However, the Fourth, Eighth, 10th, and 11th have upheld the restrictions.
