State of Minnesota v. Jayshawn Jarmell Jones, a241249

Jones was arrested at Regions Hospital after officers found a nonfunctional (unloaded at recovery), privately assembled pistol in his sweatshirt pocket; the firearm had no serial number and was marked “Combat 19” and “Polymer80.”
The firearm appeared to be a privately made "ghost gun," assembled from parts or a kit; an officer later test-fired it and found it functional.
Jones was charged under Minn. Stat. § 609.667(3) (prohibiting possession of a firearm not identified by a serial number).
He waived a jury and submitted stipulated evidence to the district court to preserve an as-applied Second Amendment challenge to the statute.
The district court denied Jones’s motion to dismiss, found him guilty, and placed him on two years’ supervised probation; Jones appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Minn. Stat. § 609.667(3), as applied to possession of a privately made firearm without a serial number, violates the Second Amendment	Jones: statute criminalizes privately made guns (ghost guns) that never had serial numbers and lacks a historical analogue	State: law fits within historical tradition of marking/recording firearms and is a permissible regulation of arms	Affirmed — statute does not violate the Second Amendment as applied; historical analogues are "relevantly similar."

District of Columbia v. Heller, 554 U.S. 570 (2008) (recognizes individual right to possess firearms for lawful purposes)
New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022) (establishes history-and-tradition test for firearms regulations)
United States v. Rahimi, 602 U.S. 680 (2024) (clarifies historical-analogue inquiry and that arms bearing was regulated at founding)
State v. Gaal, 21 N.W.3d 256 (Minn. App. 2025) (Minn. precedent holding removal of serial numbers places firearms outside typical Second Amendment protection)
State v. Vagle, 999 N.W.2d 909 (Minn. App. 2023) (uses term "ghost gun" for privately made, non-serialized firearms)
State v. Fitch, 884 N.W.2d 367 (Minn. 2016) (statutory-constitutionality review is de novo)
In re Welfare of B.A.H., 845 N.W.2d 158 (Minn. 2014) (caution in declaring statutes unconstitutional)
Republican Party of Minn. v. Klobuchar, 381 F.3d 785 (8th Cir. 2004) (limits of as-applied review)