One Gun a Month Is Gone: What Nguyen v. Bonta Means for California Buyers

In June 2025 the Ninth Circuit unanimously struck down California's one-firearm-per-30-days purchase limit. Here's what the ruling said, what's changed at the gun counter, and the caveats buyers should still keep in mind.

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 analysisDuke Center for Firearms Law litigation highlightNguyen 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.