Updated August 8, 2026. Educational information only — not legal advice. Laws and court rulings change quickly; verify current law before acting.
The short version
On June 25, 2026, the U.S. Supreme Court decided Wolford v. Lopez, ruling 6–3 that Hawaii’s so-called “vampire rule” — a law barring licensed concealed-carry holders from carrying on private property open to the public unless the owner affirmatively invited them in — violates the Second and Fourteenth Amendments. Justice Alito wrote the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett.
Why should Californians care about a Hawaii case? Because California’s SB2 contains an even stricter version of the same rule — and the dominoes have already started falling.
What the “vampire rule” was
After the Supreme Court’s 2022 Bruen decision forced “may-issue” states to start issuing carry permits, Hawaii and California responded with laws that flipped the default on private property: instead of assuming a permit holder may carry into a store or restaurant unless the owner says no, these laws assumed carry was forbidden everywhere unless the owner said yes — hence “vampire rule”: like a vampire, you couldn’t enter without an invitation. Combined with long lists of “sensitive places,” the practical effect was that a permit became nearly useless for daily life.
Hawaii at least allowed owners to give consent orally, in writing, or by posting a sign. California’s version was stricter still, recognizing consent only by posted signage.
What the Court held
The majority found that flipping the default imposed “a new and significant burden” on the right to bear arms with no historical tradition supporting it. A Ninth Circuit panel had upheld Hawaii’s rule in 2024; the Supreme Court reversed and remanded. The ruling was limited to publicly accessible private property — the Court declined to take up broader questions about sensitive-places lists in the same case. Truly private property (your home, a business closed to the public) is untouched: owners can still exclude armed patrons by making that choice themselves.
What it means for California
California’s SB2 private-property provision is functionally the twin of the law just struck down — and arguably weaker, since it gave property owners fewer ways to consent. The direct challenge to SB2, May v. Bonta (consolidated with Carralero v. Bonta), had been on hold awaiting Wolford; on July 16, 2026, it was formally reopened and returned to active litigation.
Practical guidance for CCW holders right now:
- SB2 is still on the books. Until a court formally enjoins California’s provision or the Legislature amends it, the safest course is to continue following current California law.
- Watch May v. Bonta. Given Wolford, the private-property default rule is unlikely to survive, but the timing and scope of relief are not yet settled.
- Sensitive places are a separate fight. Wolford did not resolve bans in parks, restaurants that serve alcohol, and similar locations — those SB2 provisions remain in litigation on their own track.
The bottom line
The Supreme Court has now said, clearly, that a state cannot make lawful carry disappear by declaring every shop and parking lot off-limits by default. California’s version of that rule is living on borrowed time — but it hasn’t been formally struck yet. We’ll update this article as May v. Bonta develops.
Sources: Supreme Court opinion, Wolford v. Lopez (June 25, 2026) • SCOTUSblog case page • Case background
This article is educational content from CAGUNS Resource Hub and is not legal advice. Consult a qualified attorney about your specific situation.