The Wire · CalGunHub

Ninth Circuit largely revives SB 2 sensitive-places carry restrictions

Published September 6, 2024 · Updated October 12, 2026

Deciding Wolford v. Lopez with May and Carralero, a panel left most SB 2 carry restrictions enforceable while leaving several enjoined.

Written by the CalGunHub desk from public reporting

Who this affects: Most SB 2 location restrictions on licensed concealed carry remain enforceable under this ruling, while the listed categories stayed enjoined per the panel opinion. The district court proceedings are stayed and unresolved, so the practical scope of SB 2 could still change after trial. This is general information, not legal advice.

On September 6, 2024, a Ninth Circuit panel decided Wolford v. Lopez together with May v. Bonta and Carralero v. Bonta, Nos. 23-16164, 23-4354, and 23-4356, 116 F.4th 959 (2024). According to the opinion, the panel affirmed in part and reversed in large part preliminary injunctions against California's SB 2 sensitive-places law and Hawaii's Act 52, leaving most listed carry restrictions enforceable, including bars, parks, casinos, and stadiums, while leaving enjoined California's bans as to hospitals, public transit, permitted gatherings, places of worship, financial institutions, and the private-property default rule. Rehearing en banc was denied January 15, 2025, and the mandate issued January 23, 2025. On remand, the district court stayed May on October 14, 2025, pending Wolford at the Supreme Court. The Supreme Court reversed the Ninth Circuit's Hawaii ruling on June 25, 2026; the California portions were not before the Court. 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. Final judgment has not been entered.

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