Senate Bill 2, authored by Senator Anthony Portantino, was signed by Governor Gavin Newsom on September 26, 2023, and took effect January 1, 2024.[1] It was California's legislative response to New York State Rifle & Pistol Association v. Bruen[2] (2022), in which the Supreme Court struck down New York's may-issue concealed carry permitting system and established that firearms regulations must be consistent with the historical tradition of firearms regulation in the United States.
Sensitive Places Provisions
SB 2 designated 26 categories of locations as "sensitive places" where concealed carry is prohibited even with a valid CCW permit, including:
- Government buildings, courthouses, and legislative chambers
- Schools, colleges, and universities (including parking lots)
- Places of worship (unless authorized by the operator)
- Parks, playgrounds, athletic facilities, and public recreation areas
- Hospitals, medical facilities, and mental health treatment centers
- Public transit vehicles and facilities
- Bars, restaurants serving alcohol, and entertainment venues
- Financial institutions, parking areas, and stadiums
- Polling places during elections
- Any private property where the owner has not posted explicit consent to carry
Federal Court Injunctions and the Ninth Circuit Ruling
Before SB 2 took effect, Judge Cormac Carney of the Central District of California issued a temporary restraining order in May v. Bonta (also styled Carralero v. Bonta in related proceedings), blocking most of the sensitive places provisions.[3]
On September 6, 2024, the Ninth Circuit issued its opinion in the consolidated cases of May v. Bonta, Carralero v. Bonta, and Wolford v. Lopez.[4] The panel reversed the preliminary injunction on nine additional categories of sensitive places, making SB 2's restrictions enforceable at those locations. The mandate issued on January 23, 2025. As a result, 20 of the 26 sensitive places categories are now enforceable, and only 6 remain enjoined.
What Is Now Enforceable
CCW permit holders are prohibited from carrying in the following locations, which include both categories that were never enjoined and categories where the Ninth Circuit reversed the injunction:
- Government buildings and legislative chambers
- Courthouses and judicial buildings
- K-12 schools, school grounds, and childcare facilities
- Colleges and universities
- Polling places on election days
- Airports and passenger terminals
- Law enforcement buildings
- Nuclear facilities
- Bars and restaurants serving alcohol
- Parks, playgrounds, and athletic facilities
- Youth centers
- 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
- Parking areas associated with the above locations
What Is Still Enjoined
The following six categories remain under court injunction, meaning CCW holders may still carry in these locations:
- Hospitals and medical facilities
- Public transit (buses, trains, stations)
- Places of worship (churches, mosques, synagogues, temples)
- Financial institutions (banks, credit unions)
- Gatherings that require a government permit
- Private commercial property (the default "opt-in" sign requirement remains blocked; the traditional rule that carry is permitted unless posted otherwise applies)
Practical Impact
The Ninth Circuit's ruling significantly changed the landscape for CCW holders. The majority of SB 2's sensitive places restrictions are now in effect. Permit holders must be aware that carrying in parks, restaurants serving alcohol, libraries, stadiums, and other newly enforceable locations is a violation. The private property default ban and a handful of other categories remain enjoined, but the law's overall impact on concealed carry is now substantial. A final pretrial conference was set for March 16, 2026, and further litigation could change these boundaries again.
CCW holders should consult the DOJ's current guidance[5] and their local issuing authority for the most up-to-date information on where carry is legally permitted. A Supreme Court decision in Wolford v. Lopez (argued January 20, 2026, decision expected by July 2026) will further affect the private property category -- see the section below.
Wolford v. Lopez: SCOTUS Review Pending
In October 2025, the Supreme Court granted certiorari in Wolford v. Lopez, a case challenging Hawaii's private property default rule under a framework nearly identical to SB 2's enjoined provision. Hawaii's law, like SB 2's blocked provision, prohibits concealed carry on private property unless the owner affirmatively posts permission to carry -- the reverse of the traditional "carry unless posted" default. Oral arguments were held on January 20, 2026.
A Supreme Court decision is expected by the end of the Court's term in June or July 2026. The ruling will directly affect California's SB 2 litigation: if the Court strikes down Hawaii's private property default rule, it will almost certainly invalidate SB 2's parallel provision; if the Court upholds it, California may seek to lift the existing injunction against that category. No prediction about the outcome is possible at this stage.
CCW holders should monitor this case closely. The private property default rule is one of the six currently enjoined SB 2 provisions, meaning carry on private commercial property is currently permitted unless the owner has posted a prohibition. That status may change depending on the SCOTUS ruling.
See also: SB 2 Signed Into Law: California's Post-Bruen Response
See also: How to Apply for a California CCW Permit
See also: Post-Bruen Litigation Landscape: California's Firearms Laws Under Fire