Second Amendment Update  
By Robert Phillips  
Deputy District Attorney (ret.) 

Cal. Penal Code §26230 (SB 2):  

Effective Jan. 1, 2024, the California Legislature added Penal Code §26230 (passed as SB 2), which sought to prohibit the possession of firearms in a host of locations, even when the possessor has a license to carry a concealed weapon. This led to a number of lawsuits in federal court. Some of them have been combined into one that includes a challenge to both California and Hawaii firearms statutes, Wolford v. Lopez 116 F.4th 959. California’s input into this combined lawsuit comes from the federal district court decision of May v. Bonta (C.D. Cal., Dec. 20, 2023, 709 F. Supp. 3rd 940.)  

As is the case in all the Second Amendment lawsuits lately, the debate is whether the statute at issue complies with the U.S. Supreme Court decision New York State Rifle & Pistol Association, Inc. v. Bruen (2022) 597 U.S. 1, [142 S.Ct. 2111; 213 L.Ed.2nd 387].  

As a reminder, Bruen set out the appropriate general methodology for deciding Second Amendment challenges to state laws: “When the Read More