Overview

• Judge Cathy Ann Bencivengo granted summary judgment in Hoffman v. Bonta, ruling that California’s ban on nonresidents applying for concealed-carry licenses violates the Second and Fourteenth Amendments.
• The court held that California’s argument excluding nonresidents from “the people” protected under Heller conflicts with established Supreme Court precedent.
• Applying the Bruen historical-analogue test, Bencivengo found no Founding Era laws to justify imposing a residency requirement in a general firearms licensing scheme.
• Bencivengo directed the parties to meet and submit a proposed injunction order within 30 days in accordance with her judgment.
• California’s Attorney General’s Office is preparing to appeal the decision, which contributes to a wider wave of federal challenges against the state’s strict gun licensing laws.