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) added sensitive-place restrictions in Penal Code Section 26230^[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 preliminary injunction blocking enforcement of the challenged sensitive-place 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 of the First 26 Listed Categories

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

Enforceable restrictions among the first 26 listed 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
Buildings, real property, and parking areas under the control of an airport or passenger vessel terminal, subject to the statutory transport exceptions
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 connected to enforceable locations, subject to the injunction for parking areas connected to enjoined locations and the vehicle transport and storage exceptions in PC 26230(b)-(e)
Streets and sidewalks immediately adjacent to playgrounds and youth centers, except compliant travel along a public right-of-way under PC 26230(f). That exception does not permit loitering or remaining longer than necessary to complete travel.

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. On June 25, 2026, the Supreme Court held in Wolford v. Lopez that Hawaii's private-property default rule violates the Second and Fourteenth Amendments. Other location restrictions still apply, and property owners may prohibit firearms)^[3]

The Private Property Question

SB 2's private-property provision applied to privately owned commercial establishments open to the public. It prohibited licensed carry in those establishments unless the operator clearly and conspicuously posted a sign affirmatively permitting licenseholders to carry 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. California's private-commercial-property default restriction remains enjoined. Other location restrictions still apply, and property owners may prohibit firearms.

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. A CCW license must be revoked if the licensing authority determines that the licensee has breached a condition or restriction imposed under PC 26200. Criminal liability depends on whether the conduct violates a separate criminal statute. 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. Twenty of the first 26 listed 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. California's parallel provision remains enjoined.

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 private-commercial-property default restriction remains enjoined. The Ninth Circuit upheld the injunction against SB 2's parallel provision, PC 26230(a)(26), in September 2024. On private commercial property open to the public, other location restrictions still apply, and property owners may prohibit firearms.

The decision does not address the other five enjoined categories or the twenty enforceable categories among the first 26 listed in PC 26230. 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