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 early 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; 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 traditional "carry unless posted" default currently applies in California for CCW holders.

Penalties

Carrying in an enforceable sensitive place with a valid CCW is a misdemeanor under Penal Code Section 26230(e), punishable by a fine of up to $1,000 and/or up to 6 months in county jail. A second offense within 12 months can result in CCW permit revocation. 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: Plaintiffs have petitioned for en banc rehearing at the Ninth Circuit. The 6 still-enjoined categories could become enforceable if the state prevails in further proceedings, or additional categories could be re-enjoined if plaintiffs succeed. Critically, the Supreme Court has granted certiorari in Wolford v. Lopez, a Hawaii case challenging an identical private property default rule. Oral arguments were held January 20, 2026, and a decision is expected by June or July 2026. That ruling will directly determine the fate of SB 2's private commercial property provision -- currently the most significant of the six enjoined categories.

Wolford v. Lopez: SCOTUS Review of the Private Property Rule

In October 2025, the Supreme Court granted certiorari in Wolford v. Lopez, a case challenging Hawaii's private property default rule under the same Second Amendment framework at issue in SB 2. Hawaii's law, like SB 2's enjoined 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. The Court is expected to issue its decision by the end of the 2025-2026 term, no later than July 2026. The outcome will bind California courts:

If the Court strikes Hawaii's law, the Ninth Circuit's injunction against SB 2's private property provision will almost certainly be affirmed or extended, and the traditional "carry unless posted" default will remain in California.
If the Court upholds Hawaii's law, California may petition to lift the injunction, potentially making SB 2's private property opt-in requirement enforceable.

Until the SCOTUS decision issues, private commercial property in California remains governed by the traditional rule: CCW holders may carry unless the property owner has posted a prohibition. Monitor the Court's docket for the Wolford v. Lopez ruling.

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