The Wire · CalGunHub

25 handguns added to California roster in one day under Boland court order

Published September 3, 2026 · Updated October 12, 2026

The Department of Justice listed 20 Smith and Wesson models, three SIG Sauer pistols and two Biofire smart guns, the largest single-day roster expansion since 2013.

Written by the CalGunHub desk from public reporting

Who this affects: Handguns on the roster are the models licensed dealers may generally sell to California consumers, so each addition expands the set of pistols available at retail while the listing remains active. The Sept. 3 entries were made under a court order rather than through the standard certification path, and the underlying litigation is still on appeal, which means the legal posture of these listings could change. Roster status for any specific model can be checked on the Department of Justice website. This is general information, not legal advice.

Twenty-five semiautomatic handgun models joined California's Roster of Certified Handguns on Sept. 3, 2026, the largest single-day expansion of the roster since additions effectively stopped in 2013, according to an alert from the California Rifle and Pistol Association and the Department of Justice's recently-added-models listing.

The department's listing shows multiple Smith and Wesson and Biofire entries dated Sept. 3, each carrying an asterisk, the mark the roster applies to models listed because of the federal court's order in Boland v. Bonta. According to the CRPA alert, the group comprises 20 Smith and Wesson models, including M&P 10mm M2.0 pistols in two barrel lengths, an M&P9 Shield Plus variant, four Shield X configurations, seven Bodyguard 2.0 configurations in .380 AUTO, and two Performance Center M&P9 models, plus three SIG Sauer pistols and two Biofire smart gun models designated Dark Terra and Orbital White.

The additions trace to litigation over the roster's testing requirements. In March 2023, U.S. District Judge Cormac Carney issued a preliminary injunction that barred the state from enforcing three roster requirements, chamber load indicators, magazine disconnects, and microstamping, against handguns that otherwise complied. The Ninth Circuit later paused the injunction for the first two of those requirements, so only the microstamping mandate remains unenforceable during the appeal. Because the microstamping requirement had effectively frozen new roster listings since 2013, the partial injunction opened the door to additions like the Sept. 3 group, which the department made under the court's order.

The underlying case remains pending in the Ninth Circuit. Separately, litigation trackers report that a petition in Duncan v. Bonta, the challenge to California's magazine restrictions, is before the U.S. Supreme Court. All 25 models listed Sept. 3 carry the asterisk tying them to the Boland order, according to the department's roster page.

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