SB 2 Signed Into Law: California's Post-Bruen Response

On September 26, 2023, Governor Gavin Newsom signed SB 2 into law, effective January 1, 2024. ^[1] The law was California's legislative response to the Supreme Court's decision in NYSRPA v. Bruen, which invalidated "good cause" requirements for concealed carry permits.

Key Provisions

SB 2 made sweeping changes to California's concealed carry framework:

Sensitive Places

The law designated over 25 categories of locations as "sensitive places" where concealed carry is prohibited, including:

- All public parks, playgrounds, and athletic facilities
- All places of worship (churches, mosques, synagogues, temples)
- All public libraries, community centers, and youth centers
- All hospitals, medical offices, and mental health facilities
- All public transit (buses, trains, stations, airports)
- All bars, restaurants serving alcohol, and entertainment venues
- All financial institutions (banks, credit unions)
- All parking areas associated with the above

Private Property Default Ban

SB 2 created a default prohibition on carrying on all private property unless the property owner affirmatively posts a sign or provides express consent permitting firearms. ^[2] This reversed the traditional presumption that carry is permitted unless prohibited.

Additional Requirements

- Increased training hours from 8 to 16 (initial) and 4 to 8 (renewal)
- Three character references required
- In-person psychological interview
- Liability insurance requirement
- Social media review authorized for background investigation

Immediate Legal Challenges

Multiple lawsuits were filed within days of SB 2's enactment, including May v. Bonta and Carralero v. Bonta. Federal judges issued temporary restraining orders blocking several provisions before the law took effect on January 1, 2024. Critics argued that SB 2's sensitive-places list was so expansive that it effectively nullified the right recognized in Bruen.

Litigation Outcome: 20 of 26 Sensitive Places Now Enforceable

On September 6, 2024, the Ninth Circuit issued its panel opinion in the consolidated cases of May v. Bonta, Carralero v. Bonta, and Wolford v. Lopez. ^[3] The court reversed the preliminary injunction for nine additional categories of sensitive places, finding sufficient historical analogues under the Bruen framework. The mandate issued on January 23, 2025, making those restrictions enforceable.

Combined with 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. The Ninth Circuit upheld the injunction for only six categories: hospitals, public transit, places of worship, financial institutions, permitted gatherings, and the default private property prohibition.

Plaintiffs have petitioned for en banc rehearing. A final pretrial conference was scheduled for March 16, 2026. The case continues to evolve, but the current reality is that the majority of SB 2's sensitive places restrictions are enforceable. ^[4]

Governor Newsom's Position

Governor Newsom described SB 2 as a "commonsense" measure to keep guns out of sensitive public spaces. He acknowledged that legal challenges were expected and characterized the law as part of California's ongoing effort to maintain strong firearms regulations within constitutional limits.