May v. Bonta and Carralero v. Bonta: SB 2 Sensitive Places Challenge

SB 2 took effect on January 1, 2024. Multiple lawsuits challenged the law's list of "sensitive places" where concealed carry is prohibited. The lead cases are May v. Bonta and Carralero v. Bonta, both in the Central District of California.^[1]

SB 2's Sensitive Places Provisions

SB 2 designated over two dozen categories of locations as "sensitive places" where concealed carry is prohibited, including public parks, playgrounds, churches, banks, hospitals, public transit, stadiums, libraries, zoos, museums, bars, restaurants that serve alcohol, and other privately owned commercial establishments open to the public unless the operator clearly and conspicuously posts a sign permitting licensed carry.^[2] Critics argued this effectively eliminated the right to carry recognized in Bruen by banning carry in virtually all public spaces.

Preliminary Injunctions

On December 20, 2023, just before SB 2 took effect, Judge Cormac J. Carney of the Central District of California (C.D. Cal.) issued a preliminary injunction in May v. Bonta (SACV 23-01696-CJC) and Carralero v. Bonta (SACV 23-01798-CJC) blocking several sensitive-places provisions. The district court found that many of the designated locations had no historical analog as traditional sensitive places under the Bruen framework.

Ninth Circuit Ruling (September 2024)

On September 6, 2024, the Ninth Circuit issued its opinion in May v. Bonta and Carralero v. Bonta, which were consolidated, and Wolford v. Lopez, resolving all three appeals in a single opinion.^[3] The three-judge panel reversed the preliminary injunction in significant part, making SB 2 enforceable at a majority of the designated sensitive places.

Injunction reversed (restrictions now enforceable): The panel found sufficient historical analogues to justify prohibiting carry at bars and restaurants serving alcohol, playgrounds and youth centers, parks and athletic facilities, state parks and Department of Parks and Recreation property, Department of Fish and Wildlife property, casinos and gambling establishments, stadiums and arenas, public libraries, amusement parks, zoos, and museums, along with parking areas connected to these locations. The court pointed to 19th-century park firearms bans, historical regulation of alcohol-adjacent weapons carry, and traditions of restricting firearms in places of public assembly.

Injunction affirmed (carry still permitted with CCW): The panel upheld the district court's injunction blocking restrictions at hospitals and medical facilities, public transit, gatherings requiring a government permit, places of worship, financial institutions, and parking areas connected to those locations. The panel also upheld the injunction against SB 2's default private property prohibition (the "opt-in" sign requirement), finding California's written-permission requirement too restrictive while upholding Hawaii's rule allowing permission in other forms, including orally.^[4]

Mandate and Enforcement (January 2025)

The Ninth Circuit's mandate issued on January 23, 2025. As of that date, the reversed categories became enforceable under Penal Code Section 26230(a). Combined with the categories that were never enjoined (government buildings, K-12 schools, courthouses, polling places, airports, colleges, law enforcement buildings, and nuclear facilities), 20 of the 26 sensitive places categories are now in effect.^[5]

Current Status

The Ninth Circuit denied the plaintiffs' petitions for panel rehearing and rehearing en banc on January 15, 2025. A final pretrial conference was originally set for March 16, 2026. The district court stayed the consolidated cases on October 14, 2025, lifted the stay on July 15, 2026, and set a final pretrial conference for August 17, 2027.

Supreme Court Decides Wolford v. Lopez (June 25, 2026)

On June 25, 2026, the Supreme Court decided Wolford v. Lopez, No. 24-1046, the Hawaii case resolved in the same Ninth Circuit panel opinion as the consolidated May and Carralero cases.^[6] By a 6-3 vote, in an opinion by Justice Alito, the Court held that Hawaii's rule barring licensed carry on private property open to the public absent express owner authorization violates the Second and Fourteenth Amendments. The majority explained that the rule flips the traditional common-law default for property held open to the public and lacks an adequate historical analogue, and it reversed the Ninth Circuit's judgment as to Hawaii (116 F.4th 959). Justice Barrett filed a concurring opinion. Justice Kagan dissented, and Justice Jackson filed a dissent joined by Justice Sotomayor.

For the California cases, the decision cements the injunction against SB 2's parallel private-property default, PC 26230(a)(26), which the Ninth Circuit had already left blocked. It does not decide the remaining sensitive-places categories. According to the California Rifle and Pistol Association, an organizational plaintiff, the district court proceedings in May and Carralero are resuming toward final judgment following the decision.

The practical effect for CCW holders is significant: the majority of SB 2's restrictions are now enforceable. Carrying in a park, library, stadium, restaurant serving alcohol, or similar newly enforceable location violates Penal Code Section 26230. The section carries no penalty provision of its own. A license must be revoked if the licensee breaches a condition or restriction set forth in or imposed under Section 26200. Where a location-specific criminal statute applies, carrying there may also result in prosecution under that statute. Permit holders should review the DOJ's current law enforcement bulletin and consult their local issuing authority for updated guidance.