The Ninth Circuit Court of Appeals has issued a mandate overturning California’s “one-gun-per-month” restriction. The case, Nguyen v. Bonta, challenged the California statute that only allows for the purchase of one handgun or semi-automatic centerfire rifle from a licensed dealer within a 30-day period.
The mandate order dated August 14, 2025, marks the first time the Circuit has issued a final judgment striking down a law as unconstitutional under the Second Amendment. State Attorney General Rob Bonta declined to ask the Circuit to rehear the case before the full court.
The order read in part, “Affirming the district court’s summary judgment in favor of plaintiffs, the panel held that California’s ‘one-gun-a-month’ law, which prohibits most people from buying more than one firearm in a 30-day period, facially violates the Second Amendment.”
Second Amendment Foundation (SAF) Executive Director Adam Kraut said, “This is a historic victory for Second Amendment rights in the Ninth Circuit and marks a measurable defeat for Governor Newsom and the legislature’s attempts to curtail the exercise of the right to keep and bear arms in California.”
In June, a unanimous decision from a Ninth Circuit panel ruled against the state regulation in Nguyen v. Bonta. The August 14 mandate affirms a district court’s summary judgment against the state and makes the one-in-30 regulation unenforceable.
“California has managed to do what many thought impossible: violate the Second Amendment so blatantly that even the Ninth Circuit won’t uphold it,” explained Firearms Policy Coalition (FPC) Action Foundation President Cody J. Wisniewski, counsel for FPC. “We are proud to have secured the rights of peaceable people and look forward to many more wins against California’s unconstitutional laws.”
Six private citizens, including Michelle Nguyen, for whom the case is named, participated in the suit. Gunowners’-rights groups involved in the case included the Second Amendment Foundation, the Firearms Policy Coalition, and San Diego County Gun Owners PAC. Two FFL gun dealers were also plaintiffs.
Nguyen and the others secured a summary judgment win at the district court, which California then appealed to the Ninth Circuit, where the court ruled in favor of gun owners.
Said SAF founder and Executive Vice President Alan M. Gottlieb, “This win is a huge step forward in one of the most gun-restrictive states in America, and we will not rest until Californians can exercise their full constitutional rights.”
Also from the decision, “The panel held that California’s law is facially unconstitutional because the plain text of the Second Amendment protects the possession of multiple firearms and protects against meaningful constraints on the acquisition of firearms through purchase.
“Next, the panel held that California’s law is not supported by this nation’s tradition of firearms regulation. Bruen requires a ‘historical analogue,’ not a ‘historical twin,’ for a modern firearm regulation to pass muster. Here, the historical record does not even establish a historical cousin for California’s one-gun-a-month law.”
The California Legislature enacted the one-gun-a-month law in 1999. Originally, it was focused on concealable handguns.
