Safari Club v. Bonta: California's Youth Firearms Marketing Ban Struck Down

On March 17, 2026, the U.S. District Court for the Central District of California entered final judgment in Junior Sports Magazines v. Bonta, a separate case from Safari Club International v. Bonta, permanently enjoining AB 2571, California's 2022 law that banned firearms marketing to minors ^[1].

What AB 2571 Prohibited

Signed in 2022, AB 2571 (Business and Professions Code Section 22949.80) prohibited a firearm industry member from marketing or advertising any firearm-related product in a manner that is "designed, intended, or reasonably appears to be attractive to minors" ^[2]. The law targeted:

- Advertising using "cartoons," "bright colors," or "imagery appealing to minors"
- Marketing that "reasonably appears to be attractive" to persons under 18
- Penalties of up to $25,000 per violation in civil fines

Constitutional Challenge

Multiple plaintiffs, including Safari Club International, the United States Sportsmen's Alliance Foundation, the Congressional Sportsmen's Foundation, and Junior Sports Magazines (publisher of Junior Shooters), challenged the law as a violation of the First Amendment. The plaintiffs argued the law's broad language would prohibit constitutionally protected commercial speech about lawful products. The parties stipulated to entry of final judgment and a permanent injunction.

Final Judgment and Attorney Fees

The Central District of California entered final judgment in Junior Sports Magazines on March 17, 2026. The Eastern District of California issued a separate permanent injunction in Safari Club International in an order dated March 20 and filed March 23, 2026. California was ordered to pay approximately $1.4 million in combined attorney fees and costs, consisting of $900,000 to the Junior Sports plaintiffs and $481,749.72 to the Safari Club plaintiffs ^[1]. The fee award reflects the litigation's span from 2022 to 2026.

Significance

The final judgments in both cases declared section 22949.80 unconstitutional under the First Amendment and permanently enjoined its enforcement. California argued that subsection (b) should be severed from the rest of the statute, but the Ninth Circuit held that the argument had been waived. The Ninth Circuit held that California had failed to justify section 22949.80 under the Supreme Court's commercial speech doctrine, which requires advertising restrictions to directly advance a substantial governmental interest and be no more extensive than necessary.

Official DOJ Enforcement Notice

On April 21, 2026, the California Attorney General issued Information Bulletin 2026-DLE-09 formally notifying all District Attorneys, County Counsels, and City Attorneys that the permanent injunction in Junior Sports Magazines Inc. v. Bonta, No. 2:22-cv-04663-CAS (JCx), enjoins enforcement of all provisions of California Business and Professions Code section 22949.80 ^[3]. The bulletin is the operative DOJ enforcement guidance and tells local prosecutors that enforcement of section 22949.80 has been permanently enjoined in its entirety.