SB 2 (2023):
Post-Bruen Carry Restrictions

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 preliminary injunction in May v. Bonta and the related Carralero v. Bonta case, blocking the challenged 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:

• State executive or legislative buildings and parking areas, except as allowed by Section 171c(b)(2), and local government buildings and parking areas, unless carrying for training under Section 26165
• 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
• Playgrounds and immediately adjacent streets or sidewalks. Parks, athletic areas, or athletic facilities open to the public and immediately adjacent streets or sidewalks, except when a licensee must walk through such a place to access their residence, place of business, or vehicle
• 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. On June 25, 2026, the Supreme Court held Hawaii's private-property default rule unconstitutional in Wolford v. Lopez. Under the traditional rule, those lawfully carrying firearms may enter property held open to the public unless the owner expressly prohibits it)

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 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. 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. On June 25, 2026, the Supreme Court decided Wolford v. Lopez, holding that a private-property default rule like SB 2's enjoined provision violates the Second and Fourteenth Amendments. See the section below.

Wolford v. Lopez: Supreme Court Strikes the Private Property Default

On June 25, 2026, the Supreme Court decided Wolford v. Lopez, No. 24-1046, by a 6-3 vote.^[6] Justice Alito wrote the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett. The Court held that Hawaii's rule barring licensed carry on private property open to the public unless the owner gives express 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 that the government identified no adequate historical analogue. The Ninth Circuit's contrary judgment (116 F.4th 959) was reversed and the case remanded. Justice Barrett filed a concurring opinion. Justice Kagan dissented, and Justice Jackson filed a dissent joined by Justice Sotomayor.

For California, the decision confirms the fate of SB 2's parallel provision, PC 26230(a)(26). That provision was already enjoined by the Ninth Circuit's September 2024 ruling. The Supreme Court held Hawaii's parallel private-property default rule unconstitutional. Under the traditional rule, those lawfully carrying firearms may enter private commercial property held open to the public unless the owner expressly prohibits it. The decision does not resolve the other sensitive-places categories, such as parks, bars, and public transit, which continue to be litigated in May v. Bonta and Carralero v. Bonta.

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