The Wire · CalGunHub

Ninth Circuit strikes down California one-gun-a-month purchase limit

Published June 20, 2025 · Updated October 12, 2026

A unanimous panel held Penal Code 27535's one-gun-a-month rule facially unconstitutional; the mandate issued August 14, 2025.

Written by the CalGunHub desk from public reporting

Who this affects: The judgment in this case removed Penal Code 27535's one-gun-a-month limit, and the state did not obtain further review of it. A replacement statute, AB 1078, applies a three-per-30-days limit starting April 1, 2026, so current purchase rules come from that law, not from the one struck down here. This is general information, not legal advice.

On June 20, 2025, a unanimous Ninth Circuit panel decided Nguyen v. Bonta, No. 24-2036, 140 F.4th 1237 (2025), affirming summary judgment for the plaintiffs in a challenge to California's one-gun-a-month purchase limit, Penal Code section 27535, brought in the U.S. District Court for the Southern District of California (No. 3:20-cv-02470-WQH-MMP). Judge Forrest's opinion, with a concurrence by Judge Owens, held the limit facially unconstitutional under the Second Amendment, according to the opinion and a Duke Firearms Law Center analysis. The state did not obtain rehearing, and the mandate issued August 14, 2025, the Second Amendment Foundation reported. The district court judgment striking down the law therefore stands, and no certiorari petition has been located. Separately, the Legislature enacted AB 1078 (2025), which sets a three-firearm-per-30-days limit operative April 1, 2026. As of October 12, 2026, the Nguyen judgment is final, while the newer AB 1078 framework is the operative statute going forward.

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