May v. Bonta and Carralero v. Bonta: SB 2 Sensitive Places Challenge

Following the enactment of SB 2 on January 1, 2024, multiple lawsuits were filed challenging the law's expansive list of "sensitive places" where concealed carry is prohibited. The lead cases are May v. Bonta in the Southern District and Carralero v. Bonta in the Central District.^[1]

SB 2's Sensitive Places Provisions

SB 2 designated over two dozen categories of locations as "sensitive places" where concealed carry is prohibited, including public parks, playgrounds, churches, banks, hospitals, public transit, stadiums, libraries, zoos, museums, bars, restaurants that serve alcohol, and all private property unless the owner affirmatively posts a sign permitting firearms.^[2] Critics argued this effectively eliminated the right to carry recognized in Bruen by banning carry in virtually all public spaces.

Preliminary Injunctions

In late December 2023, just before SB 2 took effect, Judge Cormac Carney in the Central District issued a temporary restraining order blocking several sensitive-places provisions. Judge Cormac Carney in the Central District (C.D. Cal.) issued a similar order in May v. Bonta (SACV 23-01696-CJC). Both courts found that many of the designated locations had no historical analog as traditional sensitive places under the Bruen framework.

Ninth Circuit Ruling (September 2024)

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.^[3] The three-judge panel reversed the preliminary injunction in significant part, making SB 2 enforceable at a majority of the designated sensitive places.

Injunction reversed (restrictions now enforceable): The panel found sufficient historical analogues to justify prohibiting carry at bars and restaurants serving alcohol, playgrounds and youth centers, parks and athletic facilities, 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, along with parking areas connected to these locations. The court pointed to 19th-century park firearms bans, historical regulation of alcohol-adjacent weapons carry, and traditions of restricting firearms in places of public assembly.

Injunction affirmed (carry still permitted with CCW): The panel upheld the district court's injunction blocking restrictions at hospitals and medical facilities, public transit, gatherings requiring a government permit, places of worship, financial institutions, and parking areas connected to those locations. The panel also upheld the injunction against SB 2's default private property prohibition (the "opt-in" sign requirement), finding no historical analogue for reversing the traditional presumption that property is open to carry unless posted otherwise.^[4]

Mandate and Enforcement (January 2025)

The Ninth Circuit's mandate issued on January 23, 2025. As of that date, the reversed categories became enforceable under Penal Code Section 26230(a). Combined with the categories that were never enjoined (government buildings, K-12 schools, courthouses, polling places, airports, colleges, law enforcement buildings, and nuclear facilities), 20 of the 26 sensitive places categories are now in effect.^[5]

Current Status

Plaintiffs have filed a petition for en banc rehearing at the Ninth Circuit, arguing that the panel's historical analysis was flawed and that several of the reversed categories lack genuine founding-era analogues. A final pretrial conference was held on March 16, 2026, in the district court. Trial scheduling is ongoing.

The practical effect for CCW holders is significant: the majority of SB 2's restrictions are now enforceable. Carrying in a park, library, stadium, restaurant serving alcohol, or similar newly enforceable location is a misdemeanor under Penal Code Section 26230(e). Permit holders should review the DOJ's current law enforcement bulletin and consult their local issuing authority for updated guidance.