Editorial: Ninth Circuit Court of Appeal Issues Order on Where Citizens with CCWs May Carry Firearms

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

Case: Wolford v. Lopez 

On Sept. 6, the Ninth Circuit Court of Appeal issued a long and comprehensive decision related to California’s and Hawaii’s efforts to regulate where private citizens with concealed weapons permits may, and may not, carry firearms – concealed or not. The statute in issue in California is Penal Code § 26230, enacted in 2023 (SB 2) and effective January 1, 2024.  

At issue in the Hawaii case, Wolford v. Lopez (9th Cir. Sep. 6, 2024) F.4th, 2024 U.S.App. LEXIS 22698, is merely whether a preliminary injunction should issue pending a final decision on the merits of the plaintiffs’ lawsuit.  

Whether a preliminary injunction should issue depends upon the “likelihood of success on the merits” when the case is finally decided. So while remembering that this decision here in Wolford v. Lopez is not necessarily how it will be decided when finally considered on the merits, it certainly gives us a window into how this lawsuit will likely be decided absent something unusual happening between now and then – like a ....

© 2026 Legal Updates, LLC.
This content is protected by copyright law. Republishing or redistribution in any form without written permission is strictly prohibited. For licensing or reprint requests, contact support@legalupdates.com.