
By Robert Phillips, Deputy District Attorney (Ret).
In November, 2021, the Ninth Circuit Court of Appeal in Duncan v. Bonta (9th Cir. 2021) 19 F.4th 1087, reversed a federal district court judge’s findings related to “large capacity magazines” (i.e., magazines that hold over 10 rounds; Pen. Code § 16740; © 2026 Legal Updates, LLC.
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