Background
Jeffrey M. Johnson, Sr., a long-haul truck driver residing in Georgia, sought to carry a firearm in Minnesota while driving through the state. Although he held permits from Georgia and Florida, Minnesota does not recognize those states’ permits. Johnson sued the Commissioner of the Minnesota Department of Public Safety, alleging the state’s reciprocity statute violated the Second Amendment. The district court dismissed the claim, and Johnson appealed.
The court’s reasoning
The court applied the two-step inquiry from New York State Rifle & Pistol Association v. Bruen. At step one, the court determined whether the challenged restriction regulates conduct covered by the Second Amendment’s plain text. The court concluded that Minnesota’s reciprocity statute does not regulate arms-bearing conduct. While the state’s general permitting requirement regulates public carry, the reciprocity statute merely exempts qualified individuals from the application process. Because the statute does not restrict any arms-bearing conduct, the government did not need to proceed to step two. The court also rejected a void-for-vagueness argument raised for the first time on appeal, noting the statute imposes no regulation or sanction for conduct.
Johnson’s Second Amendment challenge fails at Bruen step one because Minnesota’s reciprocity statute, standing alone, does not regulate arms-bearing conduct.
McCoy v. Jacobson, 25-3036 (8th Cir. May 26, 2026)
What it means going forward
The ruling confirms that states may refuse to recognize out-of-state firearm permits without violating the Second Amendment, provided the refusal does not impose additional burdens on conduct already regulated by a constitutional permitting scheme.
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