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
PC 26230 prohibits a person from carrying a firearm, whether concealed or otherwise, in any of the following locations (partial list):
- All government buildings, including courthouses, legislative chambers, and public offices
- Any building, real property, or parking area under the control of a public or private school (K-12), community college, or university
- Any building, real property, or parking area under the control of a childcare facility
- Public parks, playgrounds, and recreational areas
- Public libraries
- Public transit vehicles, stations, and platforms
- Places of worship, unless authorized by the operator
- Hospitals, medical offices, and other healthcare facilities
- Bars and restaurants that serve alcohol for on-premises consumption
- Stadiums, arenas, and entertainment venues
- Polling places on election day
- Public demonstrations and permitted events
- Zoos and museums
- Banks and financial institutions
- Parking areas of these locations
Private Property Default
The private property default appears in subdivision (a)(26) of PC 26230 itself [1]. It prohibits carry in any privately owned commercial establishment open to the public unless the operator clearly and conspicuously posts a sign indicating that licenseholders are permitted to carry firearms on the property. 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 immediately after enactment, primarily 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 issued a preliminary injunction blocking several provisions, finding that the state had not demonstrated sufficient historical support under the Bruen framework. The parallel Hawaii case, Wolford v. Lopez, was consolidated with the California appeals at the Ninth Circuit.
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):
- Government buildings, courthouses, legislative chambers
- Schools (K-12), community colleges, and universities
- Childcare facilities
- Public parks, playgrounds, and recreational areas
- Public libraries
- Bars and restaurants serving alcohol
- Stadiums, arenas, and entertainment venues
- Polling places on election day
- Zoos and museums
- Parking areas associated with these locations
- Most additional categories not listed below
The following six categories remain enjoined (NOT enforceable):
- Hospitals and healthcare facilities
- Public transit vehicles, stations, and platforms
- Places of worship (unless authorized by the operator)
- Banks and financial institutions
- Public demonstrations and permitted gatherings
- The private property default prohibition (PC 26230(a)(26))
CCW holders must be aware that carrying in any enforceable sensitive place is a criminal offense even with a valid permit. The distinction between enforceable and enjoined categories is critical. The Second Amendment Foundation and other plaintiffs have petitioned for en banc rehearing [5], and the enforceability of specific provisions may continue to evolve.
On June 25, 2026, the U.S. Supreme Court decided Wolford v. Lopez, No. 24-1046, the Hawaii case that had been consolidated with the California appeals at the Ninth Circuit.[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. The holding forecloses reviving the private property default in PC 26230(a)(26). 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 violation also exposes the licensee to revocation of the CCW license, and 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