The Wire · CalGunHub

Ninth Circuit denies en banc rehearing of SB 2 sensitive-places ruling

Published January 15, 2025 · Updated October 12, 2026

Over two dissents, the court declined to rehear May and Carralero; the mandate issued January 23, 2025.

Written by the CalGunHub desk from public reporting

Who this affects: Denial of rehearing kept the panel's SB 2 framework in effect: most listed sensitive-places restrictions enforceable, several categories still enjoined. The district court stay means the final scope of SB 2 is unsettled, and the Supreme Court's Wolford decision could shape the outcome on remand. This is general information, not legal advice.

On January 15, 2025, the Ninth Circuit denied the California plaintiffs' petitions for panel rehearing and rehearing en banc in Carralero v. Bonta and May v. Bonta, Nos. 23-4354 and 23-4356, in an order reported at 125 F.4th 1246 (2025). The order left in place the September 6, 2024 panel decision on California's SB 2 sensitive-places law. Judge Collins dissented, joined by Judge Bress, and Judge VanDyke dissented, joined by five judges, according to the order. The mandate issued January 23, 2025, giving effect to the panel ruling, as reflected in a California Department of Justice information bulletin. The cases returned to the U.S. District Court for the Central District of California, which stayed May on October 14, 2025, pending the Supreme Court's decision in Wolford v. Lopez. Wolford was decided June 25, 2026. Per the California Rifle and Pistol Association's May/June 2026 litigation report, May was combined with Carralero in June 2025 and trial was set for 2026. A final merits resolution remains pending.

Informational only, not legal advice. Facts are attributed to the sources listed above.