Second Amendment Bulletin: Federal Appeals Court Rules California’s “One-Gun-a-Month” Law Unconstitutional

Second Amendment Bulletin 
By Robert Phillips, Deputy District Attorney (Ret).

California’s “one-gun-a-month” law 
Nguyen v. Bonta (9th Cir. Jun. 20, 2025) F.4th [2025 U.S.App. LEXIS 15220]. 

In 1999, the California Legislature enacted the so-called “one-gun-a-month law.” Amended several times over the years, as of 2024, subdivision (f) of Pen. Code § 27540 reads as follows: “A firearm shall not be delivered (to a purchaser) whenever the (firearms) dealer is notified by the Department of Justice that within the preceding 30-day period (Italics added), the purchaser has made another application to purchase a handgun, semiautomatic centerfire rifle, completed frame or receiver, or firearm precursor part, and that the previous application to purchase did not involve any of the entities or circumstances specified in subdivision (b) of Section 27535.”  

In a nutshell, this says that you can only buy one gun a month unless you come within one of the 14 exceptions listed in Subdivision (b) of Pen. Code § 27535, for example, for law enforcement. Eleven plaintiffs – people who wanted to purchase more than one firearm a month, organizations whose members want to do the same, and firearm retailers and their respective owners who want to ....