Overview

• On July 1, Judge Cathy Ann Bencivengo granted summary judgment in Hoffman v. Bonta, concluding that California’s ban on concealed-carry permits for nonresidents violates the Second Amendment.
• Applying the historical-analogue test from New York Rifle & Pistol Association v. Bruen, the court found no Founding-Era precedent for excluding nonresidents from general firearms licensing schemes.
• The decision affirms that nonresidents are part of “the people” entitled to concealed-carry licenses without requiring identical fee or procedural requirements as residents.
• The court ordered both sides to meet and submit a proposed injunction within 30 days, and California may appeal the summary judgment.
• Plaintiffs’ request for relief under the Privileges and Immunities Clause was declined, focusing the ruling solely on Second Amendment grounds.