Richmond, VA – In a major reversal for gun rights advocates, the Fourth Circuit Court of Appeals has ruled that the federal ban on handgun sales by licensed dealers to adults under 21 is constitutional, effectively shutting down a key legal challenge backed by the Second Amendment Foundation.
The case, Fraser v. ATF, involved four young men between the ages of 18 and 20 who argued that their Second Amendment rights were violated when they were blocked from purchasing handguns from licensed gun shops. In 2023, Federal District Judge Robert Payne previously agreed, issuing a sweeping decision that said the ban went too far, especially after the Supreme Court’s Bruen decision made history and tradition the new test for gun laws.
But the Fourth Circuit didn’t see it that way.
232085.P Joshua McCoy v. ATF
Published opinion after argument
Author: Wilkinson
Decision: Reversed and remanded with directions to dismiss
Case Type: Civil U.S.
Appeal From: EDVA
Originating Judge: Payne
June 18, 2025
Writing for the majority, 4th Circuit Court activist Judge Harvie Wilkinson compared the modern-day ban to an old contract law rule from the founding era that voided business deals with anyone under 21 because of their supposed immaturity. He said the restriction on handgun sales is “relevantly similar” and doesn’t prevent young adults from owning or using handguns—just from buying them through licensed dealers.
In short: you can have one, just don’t expect to buy it from a gun store.
The Fourth Circuit’s June 18, 2025, decision in Fraser v. ATF (Case No. 23-2085) consolidated and resolved multiple related cases challenging the federal handgun sales ban for adults under 21.
Combined Cases in This Ruling:
- Fraser v. ATF – The lead case, originally filed by four young men in Virginia (including Justin Fraser) denied the ability to buy handguns from licensed dealers solely due to age (18–20).
- Brown v. ATF – A similar lawsuit supported by the Second Amendment Foundation, filed separately but also challenging the same age-based restriction.
- Joshua McCoy v. ATF – Another parallel case (Docket No. 23-2085.P), named in the official caption alongside Fraser and McGrath, also consolidated into this ruling.
All of these cases were decided together because they raised the same constitutional issue: whether the federal law banning handgun sales to 18–to-20-year-olds by Federal Firearms Licensees (FFLs) violates the Second Amendment under the Bruen standard.
The court reversed the lower court ruling in Fraser, rejected the plaintiffs’ claims in all related suits, and remanded the consolidated cases with instructions to dismiss.
What Changed?
Judge Payne’s original ruling was a big win for gun rights. He pointed out that there were no historical laws banning gun sales by age at the time the Second Amendment was written. He also emphasized that if you can’t buy a gun, your right to “keep” and “bear” it becomes meaningless. That decision made headlines and had gun owners hopeful that the 18–20 age-based ban would be struck down across the country.
But now, the appeals court has reversed course, and not just on Fraser. The court also tossed Brown v. ATF, another case supported by the Second Amendment Foundation.
The 4th Circuit has held that the federal 18-20 handgun purchase ban is constitutional, citing the modern day restriction is relevantly similar to the burden imposed by the founding-era rule that contracts with individuals under the age of 21 were unenforceable, and claiming that… pic.twitter.com/d54MTikYMA
— SAF (@2AFDN) June 18, 2025
The Debate Over History
Judge Wilkinson leaned heavily on old English contract law, claiming that just like merchants didn’t trust 20-year-olds to hold up a business deal, the government can reasonably block gun dealers from selling them handguns. He also noted that the law doesn’t ban private transfers, gifts, or possession—just commercial sales.
But Judge Marvin Quattlebaum dissented. He said the analogy doesn’t hold up because contract law only burdened sellers, not buyers. The federal handgun law, on the other hand, punishes FFLs and blocks adults from exercising their rights. He warned that the court was choosing policy over the Constitution.
“The right to keep and bear arms doesn’t come with an age minimum written into the Second Amendment,” Quattlebaum argued. “That’s something politicians added—now upheld by judges.”
What Happens Next?
Lawyers for the plaintiffs have said they will appeal the decision, possibly to the U.S. Supreme Court. There’s already a conflict brewing: the Fifth Circuit ruled differently earlier this year in Reese v. ATF, striking down the same federal ban as unconstitutional. That kind of split between federal courts makes it more likely the Supreme Court will eventually take up the issue.
For now, though, young adults in the Fourth Circuit—which covers Maryland, North Carolina, South Carolina, Virginia, and West Virginia—remain barred from buying handguns through gun dealers, despite being legally recognized as adults in every other area of life.
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