The Wire · CalGunHub

Supreme Court takes Hawaii carry-default case with direct SB 2 implications

Published October 3, 2025 · Updated October 12, 2026

The justices agreed to review whether states may bar licensed carriers from private property open to the public without owner permission.

Written by the CalGunHub desk from public reporting

Who this affects: The grant put California's SB 2 private-property default rule, Penal Code section 26230(b), squarely before the Court because the justices took up the same kind of restriction. That California provision applies to licensed concealed-carry permit holders and had already been enjoined by the federal courts, so it was not being enforced while the case proceeded. The Court's later decision on the Hawaii rule was expected to shape what happens next with California's parallel provision and the stayed May v. Bonta case. This is general information, not legal advice.

The U.S. Supreme Court on October 3, 2025 granted certiorari in Wolford v. Lopez, No. 24-1046, agreeing to hear a challenge to Hawaii's law that bars licensed concealed-carry permit holders from bringing handguns onto private property open to the public unless the owner gives express permission. According to the SCOTUS 2A Case Tracker, the grant was "limited to Question 1," meaning the Court will consider only the private-property default rule and not Hawaii's broader sensitive-places restrictions.

The petition sought review of a September 6, 2024 consolidated Ninth Circuit decision (116 F.4th 959) that also resolved preliminary-injunction appeals in two California cases, May v. Bonta and Carralero v. Bonta. In that ruling, the Ninth Circuit reversed most of the injunction against California's SB 2 sensitive-places list but affirmed the injunction against California's own private-property default rule, Penal Code section 26230(b). That California provision has remained enjoined, and the May v. Bonta merits case in the Central District of California was later stayed pending the Supreme Court's decision in Wolford.

The Court later set oral argument for January 20, 2026, according to the SCOTUSblog case page.

Update: The Court heard argument on January 20, 2026, and on June 25, 2026 ruled 6-3 that Hawaii's private-property default rule violates the Second and Fourteenth Amendments, reversing the Ninth Circuit. That decision is covered in a separate story in this lane.

Question 1 asks whether a state may bar licensed carriers from private property open to the public absent express owner permission. The grant set up the first Supreme Court merits review of the post-Bruen wave of state carry laws enacted after 2022, a category that includes California's SB 2, signed in 2023. The January 2, 2026 panel opinion in Baird v. Bonta also cited the cert grant in discussing the state of Second Amendment litigation in the circuit.

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