SB 2 Sensitive Places: What's Enjoined vs Enforceable

I have a California CCW permit. Where can I actually carry under SB 2, and which restrictions have been blocked by the courts?

What SB 2 Did

Senate Bill 2 (2023), codified primarily at Penal Code Sections 26230-26235^[1], was California's legislative response to NYSRPA v. Bruen (2022), which struck down New York's "proper cause" requirement for concealed carry permits. After Bruen forced California to adopt a shall-issue CCW framework, SB 2 sought to limit where permit holders could carry by designating 26 categories of "sensitive places."

The Litigation

Two primary cases challenge SB 2: May v. Bonta (C.D. Cal.) and Carralero v. Bonta (C.D. Cal.). In December 2023, Judge Cormac Carney issued a temporary restraining order blocking enforcement of most sensitive places provisions. The Ninth Circuit partially stayed this order, and subsequent rulings modified the injunction scope.

The Ninth Circuit Ruling (September 2024)

On September 6, 2024, a three-judge Ninth Circuit panel issued its opinion in the consolidated cases of May v. Bonta, Carralero v. Bonta, and Wolford v. Lopez.^[2] The panel reversed the preliminary injunction for nine additional categories of sensitive places, finding that the state demonstrated sufficient historical analogues for those locations. The mandate issued on January 23, 2025, making those restrictions enforceable.

Current Status: 20 of 26 Categories Enforceable

This section reflects the status as of July 2026. Changes are possible with future court orders.

Enforceable (carry prohibited even with CCW) -- 20 categories:

The following locations were either never enjoined or were made enforceable by the Ninth Circuit's September 2024 ruling:

Government buildings and executive/legislative offices
Courthouses and judicial buildings
K-12 schools, school grounds, and childcare facilities
Colleges and universities
Polling places on election days
Airports and passenger terminals (past security)
Law enforcement buildings (police, sheriff, highway patrol stations)
Nuclear Regulatory Commission facilities
Bars and restaurants serving alcohol
Parks, athletic areas, and athletic facilities
Playgrounds and 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 all enforceable locations
Adjacent streets and sidewalks to playgrounds and youth centers

Still enjoined (carry permitted with CCW) -- 6 categories:

The Ninth Circuit upheld the district court's injunction for these categories, meaning CCW holders may still carry at 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 (festivals, parades, demonstrations)
Private commercial property (SB 2's default "opt-in" sign requirement remains blocked, and the Supreme Court's June 25, 2026 Wolford v. Lopez decision forecloses its revival. The traditional rule that carry is permitted unless the owner posts a "no firearms" sign applies)^[3]

The Private Property Question

SB 2's most controversial provision reversed the default for private commercial property. Instead of allowing carry unless the property owner posts a "no firearms" sign (the standard in most states), SB 2 prohibited carry unless the owner posts a sign affirmatively permitting firearms. The Ninth Circuit upheld the district court's injunction against this provision, finding no historical analogue for reversing the traditional presumption. The Supreme Court reached the same conclusion on June 25, 2026, in Wolford v. Lopez, striking Hawaii's identical rule. The traditional "carry unless posted" default applies in California for CCW holders.

Penalties

Penal Code Section 26230 contains no penalty provision of its own. Where a listed location is covered by a separate criminal statute, such as school zones under PC 626.9, that statute's penalties apply. Otherwise, carrying in an enforceable sensitive place exposes the licensee to revocation of the CCW permit and to possible prosecution under California's general carry statutes. Individual law enforcement officers may not be aware of the exact injunction scope, so carrying documentation of the current court orders is advisable.

Bottom Line

Settled: The majority of SB 2's sensitive places restrictions are now enforceable. 20 of 26 categories are in effect. CCW holders must treat parks, restaurants serving alcohol, libraries, stadiums, and all other enforceable categories as no-carry zones.

Still in flux: The remaining categories continue to be litigated in May v. Bonta and Carralero v. Bonta, and boundaries could shift as those cases proceed toward final judgment. The private commercial property category, however, is now settled at the Supreme Court level. On June 25, 2026, the Court decided Wolford v. Lopez, holding that Hawaii's identical private-property default rule violates the Second and Fourteenth Amendments. That holding forecloses reviving SB 2's parallel provision.

Wolford v. Lopez: The Supreme Court Settles the Private Property Rule

On June 25, 2026, the Supreme Court decided Wolford v. Lopez, No. 24-1046, striking down Hawaii's private-property default rule by a 6-3 vote.^[5] Justice Alito wrote the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett. The Court held that barring licensed carry on private property open to the public absent express owner authorization violates the Second and Fourteenth Amendments. The majority explained that such a rule flips the traditional common-law default, under which anyone may enter property held open to the public and lacks an adequate historical analogue. Justice Barrett filed a concurring opinion. Justice Kagan dissented, and Justice Jackson filed a dissent joined by Justice Sotomayor. The Ninth Circuit's judgment upholding Hawaii's rule (116 F.4th 959) was reversed and the case remanded.

For CCW holders in California the practical rule is unchanged but now secure. SB 2's parallel provision, PC 26230(a)(26), was already enjoined by the Ninth Circuit in September 2024, and the Supreme Court's holding forecloses its revival. Private commercial property open to the public remains governed by the traditional default, meaning carry is permitted unless the property owner has posted a prohibition.

The decision does not address the other five enjoined categories or the twenty enforceable ones. Those remain subject to the ongoing May v. Bonta and Carralero v. Bonta proceedings in the district court.

Do: Follow the case dockets in May v. Bonta and Carralero v. Bonta through the California Rifle & Pistol Association^[4] or Firearms Policy Coalition websites for current injunction status. When in doubt about a specific location, err on the side of caution. Carry documentation of the current court orders.

SB 2 Sensitive Places:
What's Enjoined vs What's Enforceable