Nat. Shooting Sports Foundation, Inc. v. State of California, 235 Cal. Rptr. 3d 54

In 2007 the Legislature amended California’s Unsafe Handgun Act to designate as "unsafe" any new semiautomatic pistols that lack "dual placement microstamping" (Pen. Code §31910(b)(7)(A)), with the requirement conditioned on a Department of Justice (DOJ) certification that the technology is available to multiple manufacturers unencumbered by patent restrictions.
The DOJ issued that certification on May 17, 2013, confirming absence of patent encumbrances (the certification did not address technical feasibility).
Plaintiffs (NSSF) sued for declaratory and injunctive relief, alleging that dual placement microstamping is impossible to implement and invoking Civil Code §3531 ("The law never requires impossibilities") to seek invalidation of §31910(b)(7)(A).
The trial court granted the Attorney General’s motion for judgment on the pleadings, concluding separation-of-powers barred the action; the Court of Appeal reversed, holding a court may invalidate the statute if impossibility is proved under Civ. Code §3531.
The Supreme Court granted review to decide whether Civ. Code §3531 authorizes courts to invalidate a statute on the ground compliance is impossible; the Court assumed impossibility for purposes of the pleadings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Civil Code §3531 permits a court to invalidate a statute when complying with it is impossible	§3531 authorizes courts to declare statutes unenforceable when compliance is impossible	§3531 is an interpretive maxim only; it cannot create substantive rights or authorize invalidation of later-enacted statutes	Held: §3531 is an interpretive canon. Impossibility may justify a narrow, context-specific exception via statutory interpretation but does not authorize wholesale invalidation of a statute
Whether courts may carve out impossibility-based exceptions to §31910(b)(7)(A) after DOJ’s certification	Courts can find an impossibility exception despite DOJ’s certification	DOJ certification addressed patent availability, not technical feasibility; the statute does not permit courts to vacate the statutory mandate based on impossibility after the administrative determination	Held: The statute does not empower courts to void the statutory requirement wholesale on impossibility grounds post-certification; remedies lie in constitutional challenge or administrative mandamus to challenge the certification, not in invoking §3531 to invalidate the statute

Lewis v. Superior Court, 175 Cal.App.3d 366 (excusing statute-of-limitations compliance where timely action was impossible to effectuate legislature’s intent)
Board of Supervisors v. McMahon, 219 Cal.App.3d 286 (recognizing impossibility can excuse statutory performance; rejected claim where impossibility not shown)
Sutro Heights Land Co. v. Merced Irr. Dist., 211 Cal. 670 (statute construed to avoid requiring a public entity to work its own destruction; interpreting rather than invalidating statute)
City & County of San Francisco v. Cooper, 13 Cal.3d 898 (facial challenge to local measures must be assessed against overriding constitutional, statutory, or charter limits)
Flannery v. Prentice, 26 Cal.4th 572 (use of absurdity canon to avoid statutory constructions that produce absurd results)