Historic Defeat for California Gun Control: Ninth Circuit Rules ‘One-Gun-Per-Month’ Law Unconstitutional

One Handgun a Month

BELLEVUE, Wash. — The Second Amendment Foundation (SAF) and its partners secured a major victory today after the Ninth Circuit Court of Appeals issued a mandate overturning California’s “one-gun-per-month” restriction, setting a historic precedent.

In June, a unanimous decision from the Ninth Circuit ruled in favor of SAF and its partners in Nguyen v. Bonta, SAF’s challenge to California’s one-gun-per-month gun rationing law. SAF is joined in the case by the Firearms Policy Coalition and San Diego County Gun Owners PAC, two FFL gun dealers, and six private citizens, including Michelle Nguyen, for whom the case is named.

Background on Nguyen v. Bonta.

California’s “one-gun-per-month” law, first enacted in 1999, limited most people to buying only one handgun in any 30-day period, later expanding the restriction to include all firearms. Supporters claimed the rule would curb straw purchases and illegal gun trafficking.

In 2020, Michelle Nguyen, other individuals, two gun stores, and several pro-Second Amendment groups—including the Second Amendment Foundation (SAF), Firearms Policy Coalition, and San Diego County Gun Owners PAC—filed suit, arguing the law violated the Second Amendment.

The case reached the Ninth Circuit after SAF won a summary judgment in federal district court. In June 2025, a unanimous three-judge panel ruled that the law was facially unconstitutional, finding that the Second Amendment protects the right to own multiple firearms and to acquire them without “meaningful constraints.” The court also concluded there was no historical tradition in America supporting a law like California’s.

On August 14, 2025, the Ninth Circuit issued its formal mandate, making the decision final—marking the first time the court has struck down a gun control law outright for violating the Second Amendment.

“Today’s mandate issued by the Ninth Circuit marks the first time the court has issued a final decision striking down a law for infringing on the Second Amendment,” said SAF Executive Director Adam Kraut.

“Between Heller and Bruen, every case heard by a panel which concluded the law was contrary to the Second Amendment was reheard en banc by the court and ultimately upheld. 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.”

Nguyen v. Bonta challenges the California statute that only allows for the purchase of one handgun or semi-automatic centerfire rifle (or combination thereof), from a licensed dealer within a 30-day period. SAF secured a summary judgment win at the district court, which California then appealed to the Ninth Circuit, where the court ruled in favor of SAF and its partners.

“Today’s mandate from the Ninth Circuit is a testament to SAF’s efforts to restore the Second Amendment rights of all Americans,” 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.”

For more information visit SAF.org.


Second Amendment Foundation

The Second Amendment Foundation (saf.org) is the nation’s oldest and largest tax-exempt education, research, publishing and legal action group dedicated to safeguarding and promoting the fundamental rights of individuals enshrined in the Second Amendment of the United States Constitution. SAF engages in aggressive legal action to ensure the principles of armed self-defense, personal liberty, and the ownership of arms are defended, secured, and restored. Through public education initiatives, SAF teaches the importance of the Second Amendment to promote a society that values and exercises the right to keep and bear arms.


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SAF Wins Summary Judgement in Cal. One Gun a Month Challenge

Defending Your Second Amendment Rights: Challenging California’s One-Handgun-Per-Month Limit

F Riehl, Editor in Chief

F Riehl, Editor in Chief

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