Two Minnesota courts, ruling on the same day, sent a unified message: the structural and procedural limits on lawmaking apply to firearms regulation just as they do to any other subject, and those limits have consequences.

On May 26, 2026, the Minnesota Court of Appeals affirmed the district court’s invalidation of the state’s binary trigger ban in Minnesota Gun Owners Caucus v. Walz (A25-1507). On the same day, Ramsey County District Court Judge Leonardo Castro denied Saint Paul’s motion to dismiss a challenge to the city’s expansive firearms ordinance in Minnesota Gun Owners Caucus v. City of Saint Paul (62-CV-25-9927). Same district judge, same plaintiff, two separate defendants, and a consistent theme running through both: constitutional and statutory constraints on how gun laws are enacted and enforced are not suggestions.

Notably, neither ruling turned on the Second Amendment. Both were resolved on structural and procedural grounds, the kind that draw less public attention but often produce more durable legal results.

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The Binary Trigger Ban: Process as Substance

When the DFL-controlled Legislature banned binary triggers in 2024, it did so not through standalone legislation subject to ordinary deliberation, but by tucking the provision into a 1,400-page omnibus tax and government finance bill passed in the session’s closing minutes. The Minnesota Gun Owners Caucus, represented by the Upper Midwest Law Center, made a deliberate choice to bypass Second Amendment arguments entirely and attack the process itself.

Minnesota’s Single-Subject Clause is unambiguous: no law shall embrace more than one subject, which shall be expressed in its title. Minn. Const. art. IV, § 17. The omnibus bill was titled as legislation relating to the operation and financing of state government. The regulation of binary triggers has no cognizable relationship to the operation and financing of state government, and the state ultimately conceded the point at the motion hearing.

Judge Castro’s district court opinion was pointed, observing that if any bill demonstrated the abandonment of all bounds of reason and restraint, this was it, though out of deference to Minnesota Supreme Court precedent favoring severance, he declined to strike the entire law. The Court of Appeals, affirming on the remedy of severance rather than wholesale invalidation, expressed equivalent unease. In a companion case decided the same day, UnitedHealth Group Inc. v. State of Minnesota (A25-1398), the Court of Appeals noted the law’s provisions ranged from abortion, assisted living facilities, binary triggers, and bonds for the Iron Range to a child tax credit, college admissions, combat sports, state building codes, state patrol headquarters, straw purchasing of firearms, student parents, traffic cameras, Uber and Lyft driver pay, vaccines, and veterinary licensing, with no readily apparent unifying subject threading them together.

The immediate outcome: the binary trigger ban is enjoined. The longer-term consequence may be more significant, establishing precedent for challenging other provisions embedded in that same omnibus bill and warning future legislative majorities against using must-pass vehicles for controversial policy at the end of session.

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The Saint Paul Ordinance: Void Means Void

Saint Paul’s Ordinance 25-65 was drafted with apparent awareness of its own illegality. The city council knew that Minnesota’s firearm preemption statute, Minn. Stat. § 471.633, strips municipalities of authority to regulate firearms. Rather than pursue legislative repeal or await a change in state law, the council passed an ordinance anyway, unanimously, on November 12, 2025, covering assault weapon classifications, ghost gun restrictions, binary trigger prohibitions, and a broad sensitive-places carry ban. The city then attached a contingency provision stating that the new chapter shall not take effect or be enforced unless and until the legislature repeals Minn. Stat. § 471.633 or passes any Minnesota law that is substantially the same as any part of the ordinance or otherwise affirmatively authorizes municipalities to enact and enforce substantially similar regulations.

The city’s theory at the motion to dismiss stage: a law that is not self-executing and therefore not yet enforceable cannot violate the preemption statute. Judge Castro dispatched that theory efficiently.

The preemption statute does not speak merely to enforcement. It provides that the Legislature preempts all authority of local governments to regulate firearms, ammunition, or their respective components to the complete exclusion of any local order, ordinance, or regulation, and that any conflicting local regulation is void. Not suspended, not conditional, not merely unenforceable. Under foundational legal principles, including Norton v. Shelby County, 118 U.S. 425, 442 (1886), a void act is a nullity from inception, incapable of acquiring validity through subsequent events. The Legislature’s choice of the word void rather than unenforceable or voidable carries that established meaning under Minn. Stat. § 645.08(1). A contingency clause does not transform unauthorized action into authorized action; it is simply a delayed trigger on an act the city lacked power to take in the first place.

The sensitive-places carry prohibition runs into an independent preemption barrier under the Minnesota Citizens’ Personal Protection Act. The MCPPA does not merely preempt changes to permitting criteria. Under Minn. Stat. § 624.714, subd. 23, it bars any governmental unit from limiting the exercise of a permit to carry. An ordinance that makes possession of a firearm a misdemeanor in city libraries, parks, recreation centers, arenas, and zoos for permit holders who could otherwise lawfully carry under statewide law directly limits the exercise of that permit. The court agreed with that reading. The city’s motion to dismiss also entirely failed to address the independent preemption ground under Minn. Stat. § 624.717, which on its face supersedes municipal regulation of the carrying or possessing of pistols. The court treated that silence as a concession on a textually independent ground.

The vagueness challenge may be the most constitutionally interesting piece of the litigation. The ordinance layers three distinct notice failures. First, competing effective-date provisions, one stating the ordinance takes effect thirty days after passage and another stating it shall not take effect absent a future triggering event, with no reconciling mechanism. Second, no identified official, body, or process is responsible for determining whether the triggering condition has been met and no public announcement is required. Third, once the city claims the trigger has been satisfied, Section 225A.02(b) provides that any language in the ordinance must be deemed conformed to the substantially similar state law to the extent required for consistency, meaning the ordinance rewrites itself automatically. Citizens are therefore left to independently analyze unspecified future state legislation, determine whether the city considers it substantially the same as the ordinance, and then infer what the ordinance’s text has deemed itself to become, all before knowing whether they are in violation of a criminal ordinance. The court correctly allowed that claim to proceed.

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What These Rulings Actually Mean

These decisions are not simply favorable outcomes for gun owners. They are affirmations of constitutional structure applicable well beyond the firearms context.

The binary trigger ruling confirms that the Single-Subject Clause is a justiciable constraint, not a formality waived by a broad enough title or a cooperative legislative majority. Omnibus legislation serves legitimate functions in any complex legislative environment, but it is not a mechanism for laundering contested policy through must-pass vehicles in the session’s final hours. The structural protections at issue exist to benefit the public regardless of partisan alignment or the underlying subject matter.

The Saint Paul ruling confirms that preemption is not a preference. It is a legal ceiling on local authority. A municipality that disagrees with a state preemption determination has available remedies: legislative advocacy, political organizing, litigation. What it does not have is the authority to enact prohibited regulations on a contingent basis and wait for political conditions to activate them. That theory, if accepted, would permit any local government to maintain a library of preemption-defying ordinances in suspended animation, ready to spring into effect whenever the political environment shifts, without further democratic process or deliberation. The Legislature’s statewide uniformity judgment on firearms regulation is entitled to legal effect whether or not individual cities agree with it.

The road ahead remains uncertain. The binary trigger case may reach the Minnesota Supreme Court, where the state’s preserved arguments on the political-question doctrine and codification rule could, if adopted, substantially erode judicial enforcement of the Single-Subject Clause. The Saint Paul case proceeds toward what appears to be a strong summary judgment posture for the plaintiff. Meanwhile, the 2026 legislative session is reportedly considering semi-automatic and magazine capacity restrictions, measures that, if enacted through proper single-subject legislation, would present a materially different legal challenge than the one resolved here.

May 26 reaffirmed a straightforward but often underenforced proposition: procedural legitimacy is not separate from substantive lawmaking. It is a prerequisite to it.