Horsley v. Trame

A few months after Horsley turned 18, she mailed in an application for an Illinois Firearm Owner’s Identification Card (FOID) card along with the requisite check for $10. Horsley’s application was returned to her with a letter, informing her that the application was incomplete because she was not yet 21 years old and her application did not contain the signature of a parent or guardian. Horsley did not appeal or seek further review from the Director of the Illinois State Police, but filed suit, alleging that the Illinois statutory scheme violated her rights under the Second Amendment. The district court and Seventh Circuit rejected her claims. Illinois does not impose a categorical ban on firearm possession for 18-to- 20-year-olds whose parents do not consent. When an applicant cannot obtain a parent or guardian signature, he may appeal to the Director for a FOID card; the process for 18-to-20-year-olds is not unconstitutional. View "Horsley v. Trame" on Justia Law