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Ninth Circuit Annihilates California’s ‘One-Gun-A-Month’ Law

News2A Team
June 23, 2025
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In layman’s terms: The U.S. Court of Appeals for the Ninth Circuit determined that limitations on the purchase of multiple firearms are unconstitutional.

On June 20, the U.S. Court of Appeals for the Ninth Circuit struck down California’s “one-gun-a-month” law, which prohibits most individuals from purchasing more than one firearm within any 30-day period, declaring it unconstitutional under the Second Amendment.

The panel’s 3-0, 24-page ruling in Nguyen v. Bonta, applied the framework from New York State Rifle & Pistol Association v. Bruen and concluded 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.”

In an important finding that will be relevant to other states with limitations on how frequently firearms may be purchased, like New Jersey, the panel found that “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.”

Per the Bruen doctrine, the court examined historical analogues presented by California, such as 17th-century laws limiting firearm carrying near Native towns and 19th-century restrictions on sales to certain groups, but found them not “relevantly similar” to the broad, categorical restriction on all individuals.

The panel discarded these analogues by acknowledging that the Second Amendment protects acquisition rights, and writing, “The federal handgun purchase ban implicates the Second Amendment’s text because 18- to 20-year-olds are part of ‘the people’… a ban on purchasing infringes the right to ‘keep and bear’ arms.”

The panel excoriated California for rationing rights to its residents as though it were a beneficent overlord:

California suggests that the Second Amendment only guarantees a right to possess a single firearm, and that Plaintiffs’ rights have not been infringed because they already possess at least one firearm. California is wrong.

Implications for New Jersey’s Pistol Purchase Permit System

If California is wrong, then so are other states that have similar limitations.

New Jersey’s firearm laws require individuals to obtain a firearms purchaser identification card (FPIC) and a permit to purchase a handgun for each handgun purchase. The permit is valid for 90 days, but limits handgun purchases to one every 30 days.

This limitation was challenged in a lawsuit brought by the Coalition of New Jersey Firearms Owners (CNJFO), Gun Owners of America, Gun Owners Foundation, along with private plaintiff Christian Benton, in a case known as Benton v. Platkin. The Benton case has since been dismissed, with the exception of the OGAM count. Firearms Policy Coalition (FPC) also filed suit against New Jersey’s “one handgun per month” prohibition in September of 2024.

Although New Jersey’s restrictions are related to a permit process rather than a flat purchase limit, they will surely be implicated by the “meaningful constraint” conclusion of the Ninth Circuit on the right to acquire multiple firearms, as identified in Nguyen v. Bonta.

“As this decision shows, the right to keep and bear arms cannot be limited by an arbitrary cap on the number of guns that can be acquired at one time,” explained FPC President Brandon Combs in a press statement. “We have a right to buy more than one gun at a time, just as we have a right to buy more than one bible at a time. FPC is proud to have secured the rights of peaceable people and will continue to fight forward until we eliminate immoral laws like this everywhere.”

The ruling is specific to California’s law and does not address other potential restrictions, as noted in Judge Owens’ concurrence.