Rhode v. Bonta — Ninth Circuit panel strikes ammo background check (under en banc review)
effective July 24, 2025
A Ninth Circuit panel affirmed a permanent injunction against California's Proposition 63 ammunition background-check regime (Penal Code § 30370), holding it violates the Second Amendment. On December 1, 2025 the Ninth Circuit granted California's petition for rehearing en banc; oral arguments are scheduled for the week of March 23, 2026. The ammunition eligibility check therefore remains in effect during the rehearing.
Rhode v. Bonta, No. 24-542 (9th Cir.)
Carralero v. Bonta — non-residents may apply for California CCW
effective April 22, 2025
Pursuant to a federal court order in Carralero v. Bonta, the California DOJ began allowing eligible non-residents to apply for a California concealed-carry license on April 22, 2025. Applicants must apply in a California jurisdiction in which they intend to spend time within the subsequent 12 months and attest to that intention under oath. The order does not create outbound reciprocity and does not require California to honor any out-of-state permit.
Carralero v. Bonta (C.D. Cal.)
Duncan v. Bonta — Ninth Circuit (en banc) upholds 10-round magazine ban
effective March 20, 2025
The en banc Ninth Circuit, 7-4, upheld California's large-capacity magazine ban (Penal Code § 32310), holding that magazines holding more than 10 rounds are 'accessories' rather than 'arms' for Second Amendment purposes and that, in any event, the ban is consistent with the Nation's historical regulatory tradition. The plaintiffs petitioned the U.S. Supreme Court for certiorari on August 17, 2025; the case is pending.
Duncan v. Bonta, No. 23-55805 (9th Cir. Mar. 20, 2025) (en banc)
Wolford v. Lopez — Ninth Circuit largely upholds SB 2 sensitive-places list
effective September 6, 2024
Decided alongside May v. Bonta and Carralero v. Bonta, the Ninth Circuit reversed most of the district-court preliminary injunction against California's § 26230 sensitive-places list, holding that bars, restaurants serving alcohol, playgrounds, parks, athletic venues, casinos, stadiums, public libraries, amusement parks, zoos, and museums fall within the historical tradition of 'sensitive places.' The court affirmed the injunction for a narrower set of categories, including the default 'no-carry' rule on private commercial property absent posting. The U.S. Supreme Court granted certiorari in the companion Hawaii case (Wolford v. Lopez) on October 3, 2025.
Wolford v. Lopez, No. 23-16164 (9th Cir. Sept. 6, 2024)
AB 28 (Gabriel) — 11% firearms and ammunition excise tax
effective July 1, 2024
The Gun Violence Prevention and School Safety Act imposes an 11% California excise tax on retail sales of firearms, firearm precursor parts, and ammunition by California dealers, manufacturers, and ammunition vendors. Revenue is dedicated to violence prevention and school safety programs. Active and retired peace officers and quarterly sales under $5,000 are exempt.
Chapter 231, Statutes of 2023 (AB 28)
SB 2 (Portantino) — post-Bruen CCW rewrite and sensitive-places list
effective January 1, 2024
Chapter 249 of the Statutes of 2023 replaced California's 'may-issue / good cause' concealed-carry regime with a shall-issue scheme keyed to objective disqualifiers (§ 26202), raised the new-applicant training minimum to 16 hours including live fire (§ 26165), and added the § 26230 sensitive-places list. A federal preliminary injunction was issued December 20, 2023; the Ninth Circuit largely reversed the injunction in Wolford v. Lopez (Sept. 6, 2024).
Chapter 249, Statutes of 2023 (SB 2)
AB 1621 (Gipson) — unserialized 'ghost gun' criminalization
effective January 1, 2024
Effective January 1, 2024, possession of a firearm not bearing a state- or federally-issued serial number became unlawful. Individuals who previously self-manufactured a firearm had to apply to the DOJ for a unique identifier under Penal Code § 29180 before that date. AB 1621 also bars the sale or transfer of unserialized firearm precursor parts and restricts CNC equipment used to mill firearms from being sold to non-licensees.
Chapter 76, Statutes of 2022 (AB 1621)