Hawaii’s age-21 gun law survives Second Amendment challenge

U.S. District Judge Jill Otake, a Trump appointee, upheld Hawaii's law requiring gun buyers to be 21, ruling against Honolulu resident Juda Roache and two gun dealers who challenged it under the Second Amendment. Otake found the restriction consistent with the nation's historical tradition of firearm regulation under the Supreme Court's Bruen framework, citing founding-era contract law that let people under 21 void purchases of non-necessities, including pistols, and a wave of post-Civil War state laws banning gun sales to people under 21.

Otake acknowledged 18- to 20-year-olds are part of the constitutional class the Second Amendment protects, rejecting a threshold argument that could have ended the case for Hawaii outright, and noted old militia laws cut both ways on the historical question. The ruling adds to a growing circuit split, with the Fifth Circuit having struck down a similar federal law while the Fourth, Eighth, Tenth and Eleventh Circuits have upheld comparable restrictions.

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