SAN FRANCISCO, CA (May 4, 2021) — Today, Firearms Policy Coalition (FPC) announced the completion of the supplemental briefing ordered by the Ninth Circuit Court of Appeals in Jones v. Bonta, FPC’s Second Amendment lawsuit challenging California’s age-based ban on firearms purchases by law-abiding adults under the age of 21. The briefs can be viewed at

On March 26, the Ninth Circuit ordered the parties in Jones to file supplemental briefs addressing the following topics:

  1. What is the original public meaning of the Second Amendment phrases: “A well regulated Militia”; “the right of the people”; and “shall not be infringed”?
  2. How does the tool of corpus linguistics help inform the determination of the original public meaning of those Second Amendment phrases?
  3. How do the data yielded from corpus linguistics assist in the interpretation of the constitutionality of age-based restrictions under the Second Amendment?

On April 23, the appellants filed their supplemental brief responding to the Court’s questions, which stated that “there can be no question that the original public meaning of this Second Amendment phrase encompasses—and forbids—the restrictions on firearm acquisition imposed by California in this case.”

The appellants’ response brief argues that California “agrees that the tool of corpus linguistics does little to illumine the original meaning of the phrases in question,” and “should the Court nonetheless decide to consult corpus linguistics, the data derived from that method only confirm the meaning established by Heller and traditional originalist methods.”

“The Supreme Court has made clear that the Second Amendment’s ‘prefatory clause does not limit or expand the scope of the operative clause,’” said FPC’s Director of Constitutional Studies, Joseph Greenlee. “In other words, the phrase ‘A well regulated Militia’ does not change the fact that the right belongs to all Americans. Additionally, the Court has made clear that the militia in colonial America was a subset of ‘the people.’ And because 18-to-20-year-olds were included in every colonial and founding-era militia, they are clearly a part of ‘the people’ protected by the right. As our briefing plainly demonstrates, a corpus linguistics analysis does nothing to change that. At FPC, we envision a world of maximal individual liberty. Today’s brief exemplifies that idea, and we are eager for this courtand courts across the nationto adopt that same vision.” 

Oral arguments in Jones are scheduled to take place virtually on May 12 before Judges Ryan D. Nelson, Kenneth K. Lee, and Sidney H. Stein. 

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Firearms Policy Coalition and its FPC Law team are the nation’s next-generation advocates leading the Second Amendment litigation and research space. Some FPC legal actions include:

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Firearms Policy Coalition (, a 501(c)4 nonprofit organization, exists to create a world of maximal human liberty, defend constitutional rights, advance individual liberty, and restore freedom. FPC’s efforts are focused on the Right to Keep and Bear Arms and adjacent issues including freedom of speech, due process, unlawful searches and seizures, separation of powers, asset forfeitures, privacy, encryption, and limited government. The FPC team are next-generation advocates working to achieve the Organization’s strategic objectives through litigation, research, scholarly publications, amicus briefing, legislative and regulatory action, grassroots activism, education, outreach, and other programs. FPC Law (, the nation’s largest public interest legal team focused on the Right to Keep and Bear Arms, lead the Second Amendment litigation and research space.