Updated August 8, 2026. Educational information only — not legal advice. Verify current law before acting.
What happened
On June 20, 2025, a unanimous three-judge panel of the Ninth Circuit decided Nguyen v. Bonta, holding that California’s ban on purchasing more than one firearm in any 30-day period violates the Second Amendment. The court affirmed the district court’s judgment against the law.
The reasoning was blunt: applying the Supreme Court’s Bruen test, the panel found that the historical record did not establish even a “historical cousin” for rationing how often a law-abiding citizen may acquire arms. The Second Amendment protects the right to keep arms — plural — and a metering scheme on lawful acquisition found no support in the American regulatory tradition.
A little history
California’s one-in-30 rule started in 1999 as a handgun-only limit and was expanded in recent years to cover semiautomatic rifles and then essentially all firearm transactions. What began as an anti-trafficking measure ended up sweeping in collectors, sport shooters, and anyone buying a pair of firearms in a single trip.
Notably, C&R collectors holding an FFL03 plus a COE already enjoyed a statutory exemption from the limit for curio and relic handguns — one of the classic perks of the collector combo. Nguyen extended relief to everyone else.
What it means at the counter
- The 30-day purchase meter no longer blocks transactions. Following the ruling, dealers are again able to process multiple firearm purchases without the one-per-month restriction.
- Everything else still applies. DROS, the background check, the 10-day waiting period, the FSC requirement, and (for handguns) the roster all remain in force. Nguyen touched only the purchase-frequency cap.
- Dealer software and habits lag. Some retailers were slow to update policies after the ruling; if you hit friction, ask politely and point to the decision.
Caveats worth knowing
The State of California did not simply accept the loss, and litigation postures can shift — en banc petitions and Supreme Court review are always possibilities in this circuit, and legislatures sometimes respond to a struck statute with a redrafted one. Before making plans that depend on buying multiple firearms in a short window, take two minutes to confirm nothing has changed. We’ll keep this article updated.
The bigger picture
Nguyen was one of a string of 2025–2026 decisions reshaping California gun law — alongside Rhode v. Bonta (ammunition background checks), Baird v. Bonta (open carry, now en banc), and the Supreme Court’s Wolford v. Lopez (carry on private property). Taken together, they mark the most active period for Second Amendment litigation in the state’s history.
Sources: Snell & Wilmer analysis • Duke Center for Firearms Law litigation highlight • Nguyen v. Bonta, 24-2036 (9th Cir. June 20, 2025)
This article is educational content from CAGUNS Resource Hub and is not legal advice. Consult a qualified attorney about your specific situation.
What the Community Is Saying
The CAguns thread opened the day the Ninth Circuit ruled in June 2025. It is worth revisiting for an uncomfortable reason: the members who refused to celebrate turned out to be right.
The panel composition was the real news
Members focused less on the outcome than on how it was reached — a unanimous panel that included an Obama appointee, finding no pertinent historical analogue for a time-based cap on purchases. The argument was that a 3–0 decision resting on the absence of any historical tradition is harder to unwind en banc than a split one.
Nobody trusted it to last, and they were right
Two predictions dominated the skeptical replies. First, that the Ninth Circuit has shown considerable appetite for taking firearm cases en banc. Second — more specifically — that the Legislature already had replacement language drafted with contingency triggers, ready to switch on the moment the one-gun limit fell. That is exactly what happened: AB 1078's three-per-thirty-days cap took effect April 1, 2026. The practical advice offered at the time, to go buy while the window was open, was sound.
What the replacement actually looks like at the counter
A later thread has the detail this article's readers will most want. A member bought two handguns on April 1, 2026, then attempted a two-gun private party transfer on April 25. The dealer ran them as separate DROS transactions; one cleared the ten days, the second was held and had to be re-submitted after thirty. The lesson members drew: splitting transactions accomplishes nothing, because the system counts firearms rather than paperwork. Two further points got settled there — private party transfers get no exemption under Penal Code § 27535, and FFL03 plus COE holders do remain exempt.
Opened the day of the Ninth Circuit opinion · CAguns.net
1-in-30 Law Struck Down by 9th Circuit
Bought more than one firearm since April 1? Post how your dealer counted it.
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