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 (consolidated with 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 any person 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 National Rifle Association, 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. California conceded the law was unconstitutional and agreed to a permanent injunction.

Final Judgment and Attorney Fees

The court entered final judgment on March 17, 2026, permanently enjoining enforcement of AB 2571. California was ordered to pay approximately $1.4 million in combined attorney fees, including $481,000 to the NRA ^[1]. The fee award reflects the litigation's span from 2022 to 2026.

Significance

AB 2571's permanent enjoinment is notable as a concession. California did not attempt to defend the law's constitutionality after the district court's initial ruling. The case establishes that states cannot broadly restrict commercial speech about lawful firearms products based on content that might appeal to minors, consistent with the Supreme Court's commercial-speech doctrine requiring that advertising restrictions directly advance a substantial governmental interest through means 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 confirms that no local prosecutor may enforce AB 2571 / B&P 22949.80.