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The Supreme Court has declined to hear a challenge to Minnesota’s concealed carry reciprocity policy, leaving travelers to navigate the same state-by-state patchwork that existed before the case.
The Court denied Jeffrey M. Johnson Sr.’s petition in Johnson v. Jacobson on October 5 without offering an explanation. The decision leaves the Eighth Circuit’s ruling in place.
However, the denial does not mean the Supreme Court found Minnesota’s law constitutional. A denial of certiorari is not a ruling on the merits.
NSSF Senior Vice President and General Counsel Larry Keane says the outcome places renewed pressure on Congress to pass national concealed carry reciprocity.

Table of contents
The Case Behind the Decision
Johnson is a Georgia resident and long-haul truck driver who regularly travels through Minnesota. He holds valid concealed carry permits from Georgia and Florida, but Minnesota recognizes neither permit.
Minnesota issues permits to residents and nonresidents. It also honors permits from states that meet its reciprocity standards.
Johnson challenged the state’s refusal to recognize his existing permits. He argued that requiring another permit placed an additional burden on his Second Amendment rights.
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The Eighth Circuit rejected that argument in May. The court noted that Johnson did not challenge Minnesota’s underlying shall-issue permitting system. Because of that concession, the court treated reciprocity as an exemption from Minnesota’s permit requirement, not an independent Second Amendment right.
The panel acknowledged that a different constitutional issue could arise if a state refused to issue permits to nonresidents while also refusing to recognize permits from other states. Minnesota allows nonresidents to apply, so that question was not before the court.
Safe Passage Does Not Mean Carry
Federal law already provides limited protections for firearm owners traveling across state lines.
Under the federal safe-passage law, qualified travelers may transport unloaded and inaccessible firearms between places where they may legally possess them.
ATF proposed a rule in May clarifying that overnight lodging, fuel stops, repairs, medical treatment and other necessary travel activities can remain protected. However, the proposal deals with firearm transportation, not carrying a loaded handgun for self-defense.
Reciprocity Bills Remain in Congress
NSSF is calling for passage of the Constitutional Concealed Carry Reciprocity Act.
The House version, H.R. 38, would generally allow qualified individuals to carry concealed handguns in other states that permit concealed carry. Travelers would still need to follow the destination state’s rules concerning where and how firearms may be carried.
The House Judiciary Committee approved an amended version in 2025. It was formally reported to the House on October 3, 2025, but has not received a floor vote. The Senate companion, S. 65, was introduced by Sen. John Cornyn of Texas but has not advanced beyond the Senate Judiciary Committee.
NSSF’s position is straightforward: lawful carriers should not need several permits and a legal roadmap simply to cross state lines.
With the Supreme Court declining to take Johnson’s case, any nationwide solution will likely have to come from Congress. As always, stay tuned for updates.
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