PC 26230:
Sensitive Places Carry Restrictions (SB 2)

California Penal Code Section 26230 ^[1] was enacted as part of Senate Bill 2 (2023) ^[2], California's legislative response to the U.S. Supreme Court's decision in NYSRPA v. Bruen. While the legislature was forced to remove the "good cause" requirement for CCW issuance, SB 2 simultaneously created extensive restrictions on where CCW holders may carry.

Prohibited Locations

A person granted a license under PC 26150, 26155, or 26170 shall not carry a firearm on or into the places listed in PC 26230, subject to the statute's exceptions. The following partial list describes the statutory text. The injunctions discussed below apply.

- Buildings or portions of buildings under the control of state executive or legislative officers, except as allowed by PC 171c(b)(2), court buildings unless the licenseholder is a justice, judge, or commissioner of that court, and local-government buildings unless the firearm is carried for training under PC 26165
- Places prohibited by PC 626.9, including K-12 school grounds, and areas under the control of a public or private community college, college, or university
- Any building, real property, or parking area under the control of a preschool or childcare facility, subject to the family-home childcare exception in subdivision (a)(2)
- Playgrounds, youth centers, and parks, athletic areas, or athletic facilities open to the public, including the adjacent streets or sidewalks specified in subdivisions (a)(11) and (12), subject to the access exception in subdivision (a)(12)
- Public libraries
- Publicly funded transportation and transportation-authority property, subject to the unloaded-firearm transport exception in subdivision (a)(8)
- Places of worship unless the operator posts the sign required by subdivision (a)(22)
- Hospitals, medical offices, and other healthcare facilities
- Bars and restaurants that serve alcohol for on-premises consumption
- Stadiums, arenas, and real property or parking areas under the control of a stadium, arena, or collegiate or professional sporting or eSporting event
- Polling places, voting centers, precincts, and other locations where votes are cast or cast ballots are returned or counted, and immediately adjacent streets or sidewalks
- Public gatherings or special events on property open to the public requiring a government permit, and the immediately adjacent sidewalk or street within 1,000 feet, subject to the access exception in subdivision (a)(10)
- Zoos and museums
- Banks and financial institutions
- Parking areas specified in these provisions, subject to the vehicle and parking-area exceptions in subdivisions (b) and (c)

The vehicle and parking-area exceptions do not apply under subdivisions (a)(21) or (a)(28). The statute also permits travel along a public right-of-way that touches or crosses the listed premises, except college or university areas under subdivision (a)(14), when the firearm is carried or transported as the statute requires. It does not permit loitering or remaining longer than necessary to complete the travel. Carrying otherwise expressly authorized by law is not prohibited by this section.

Private Property Default

The private property default appears in subdivision (a)(26) of PC 26230 itself ^[1]. It prohibits carry in any other privately owned commercial establishment open to the public unless the operator clearly and conspicuously posts a sign at the entrance of the building or on the premises indicating that licenseholders are permitted to carry firearms on the property. The sign must be of a uniform design prescribed by the Department of Justice and at least four inches by six inches in size. This reverses the traditional default, under which carry was permitted on private property unless the owner prohibited it.

Federal Court Challenges and Current Enforceability

Multiple provisions of SB 2 were challenged in federal court in May v. Bonta and Carralero v. Bonta (C.D. Cal.). On December 20, 2023, Judge Cormac J. Carney of the U.S. District Court for the Central District of California granted the requested preliminary injunction against the challenged provisions in an opinion applying the Bruen framework. The Ninth Circuit consolidated the two California cases and issued a single panel opinion addressing them and the parallel Hawaii case, Wolford v. Lopez.

On September 6, 2024, the Ninth Circuit issued its opinion in the consolidated cases, partially reversing the district court's preliminary injunction ^[4]. The appellate panel found sufficient historical analogues for many of the listed sensitive places but upheld the injunction as to six categories. The mandate issued on January 23, 2025, making the ruling effective.

As of January 2025, the following provisions are enforceable (20 of 26 categories):

- State executive or legislative buildings, court buildings, and local-government buildings covered by subdivisions (a)(3)-(5), subject to the exceptions stated above
- Places prohibited by PC 626.9, including K-12 school grounds, and public or private community college, college, or university areas
- Preschools and childcare facilities, subject to the family-home exception
- Playgrounds, youth centers, and parks, athletic areas, or athletic facilities open to the public, subject to the access exception stated above
- Public libraries
- Bars and restaurants serving alcohol
- Stadiums, arenas, and real property or parking areas under the control of a stadium, arena, or collegiate or professional sporting or eSporting event
- Polling places, voting centers, precincts, and other locations where votes are cast or cast ballots are returned or counted, and immediately adjacent streets or sidewalks
- Zoos and museums
- Parking areas specified for these locations, subject to the vehicle and parking-area exceptions stated above
- Other specifically listed locations outside the six enjoined categories, subject to statutory exceptions. Subdivisions (a)(27)-(29) also refer to places prohibited by other state, federal, or local law

The following six categories remain enjoined (NOT enforceable):

- Hospitals and healthcare facilities
- Public transit vehicles, stations, and platforms
- Places of worship
- Banks and financial institutions
- Public gatherings or special events requiring a government permit
- The private property default prohibition (PC 26230(a)(26))
The injunction also covers parking areas and similar areas connected to the medical, transit, worship, financial-institution, and permitted-gathering categories.

CCW holders may not carry in a place covered by an enforceable prohibition unless a statutory exception applies. PC 26230 does not set a penalty of its own, so any criminal charge depends on another statute. The distinction between enforceable and enjoined categories is critical. The Second Amendment Foundation and other plaintiffs petitioned for en banc rehearing, which the Ninth Circuit denied on January 15, 2025 ^[5].

On June 25, 2026, the U.S. Supreme Court decided Wolford v. Lopez, No. 24-1046, the Hawaii case that the Ninth Circuit addressed in the same panel opinion as the consolidated California appeals.^[6] By a 6-3 vote, in an opinion by Justice Alito, the Court held that a rule barring licensed carry on private property open to the public absent express owner authorization violates the Second and Fourteenth Amendments. Wolford holds that Hawaii's private property default violates the Second and Fourteenth Amendments. California's PC 26230(a)(26) remains covered by the preliminary injunction. It does not decide the other sensitive-places categories, which remain in litigation.

Penalties

PC 26230 does not prescribe a criminal penalty of its own. Several listed locations are covered by separate statutes with independent penalties, such as school zones under PC 626.9 and public buildings under PC 171b. A licensee who violates a criminal law while carrying breaches a license condition, and the licensing authority must then revoke the license. Prosecutors may pursue general carry charges such as PC 25400 (concealed carry) or PC 25850 (loaded carry) where the carry falls outside the scope of the license.

See also: SB 2 (2023): Post-Bruen Carry Restrictions

See also: SB 2 Signed Into Law: California's Post-Bruen Response

See also: SB 2 Sensitive Places: What's Enjoined vs What's Enforceable

See also: May v. Bonta and Carralero v. Bonta: SB 2 Sensitive Places Challenge