Baughcum v. Jackson, No. 22-13444 (11th Cir. 2024)Annotate this Case
In this case, three individuals and the Firearms Policy Coalition (FPC), an advocacy group, challenged a Georgia law that prohibits individuals under the age of 21 from obtaining licenses to carry firearms. They sued three county probate judges, who issue carry licenses, and Georgia’s Commissioner of Public Safety, who designs the carry license application form. The district court dismissed the case, concluding that the plaintiffs lacked standing to sue any of the defendants and that the case was both moot and unripe. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs have standing to sue the probate judges, but not the Commissioner of Public Safety. The court found that the plaintiffs' alleged injury - the inability to carry firearms due to their age - is traceable to the actions of the probate judges who issue the licenses, and could be redressed by a court order directed at them. However, the court held that the plaintiffs' injuries are not fairly traceable to, nor redressable by a court order against, the Commissioner of Public Safety, who merely designs the application form and lacks enforcement authority. The court also held that the case was neither moot nor unripe with respect to the probate judges, reversing the district court's dismissal of the case in part and remanding the case to the district court for further proceedings.