Christopher Baughcum, Jr. v. Genola Jackson, 92 F.4th 1024

Three individuals under age 21 and the Firearms Policy Coalition (FPC) challenged Georgia’s law prohibiting those under 21 from obtaining gun carry licenses.
The plaintiffs allege the age restriction violates their Second Amendment rights, as they are otherwise eligible and wish to carry firearms.
They sued three county probate judges (who issue licenses) and the Commissioner of Public Safety (who designs license forms).
The district court dismissed the case, holding plaintiffs lacked standing, the claims were moot (since the law changed), and the case was unripe (no application/denial occurred).
Georgia’s licensing law now allows permitless carry for those eligible for a license, but under-21 adults are still not eligible for a license, leaving them excluded.
On appeal, during pendency, two plaintiffs turned 21 (potentially mooting their claims), but one remained underage; FPC claims to have other similarly situated members.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Standing to sue Commissioner	Commissioner involved in designing forms; enforces law	Commissioner is too far removed; cannot grant relief	No standing against Commissioner.
Standing to sue probate judges	Judges directly deny licenses; formality of application is futile	No injury w/o application; judges are immune	Standing exists; judges’ role is ministerial, not judicial, so no immunity bar.
Ripeness	Futile to apply; face credible threat of enforcement	Not ripe w/o application/denial or prosecution	Claims are ripe; application would be futile, credible threat suffices for ripeness.
Mootness after licensing law change	Under-21s still excluded; controversy remains	Permitless carry moots case; licensing regime changed	Not moot; under-21s still have only route via denied license.
Mootness after plaintiffs turn 21	At least one plaintiff, plus members, remain underage	Those turning 21 moot their claims	At least one live plaintiff, so case not moot; FPC membership confers standing.

Lujan v. Defs. of Wildlife, 504 U.S. 555 (standing requirements of injury in fact, traceability, and redressability)
Spokeo, Inc. v. Robins, 578 U.S. 330 (nature of concrete and particularized injury for Article III standing)
Carney v. Adams, 592 U.S. 53 (futility exception applies if application would be inevitably denied)
Susan B. Anthony List v. Driehaus, 573 U.S. 149 (credible threat of prosecution constitutes injury in fact in pre-enforcement challenges)
Moose Lodge No. 107 v. Irvis, 407 U.S. 163 (standing requires actual or planned injury from the challenged policy)
Allen v. Wright, 468 U.S. 737 (injury must be judicially cognizable and traceable to defendant)