Nguyen v. Bonta, 140 F.4th 1237

Background

California enacted a “one-gun-a-month” law prohibiting most individuals from purchasing more than one firearm within any 30-day period, originally applying only to handguns, later expanded to all firearms.
The law aimed to curtail straw purchases and illegal gun trafficking by limiting the frequency of legal gun acquisitions.
Plaintiffs, including individuals, organizations, and gun retailers, challenged the law as a facial violation of the Second Amendment.
The district court granted summary judgment for Plaintiffs, finding the law unconstitutional under recent Supreme Court precedents.
The State of California appealed, arguing the law fit within traditions of firearms regulation and did not meaningfully burden Second Amendment rights.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether limiting firearm purchases to one per 30 days violates the Second Amendment	The law imposes a meaningful constraint on the acquisition and possession of multiple firearms, which is protected by the Second Amendment.	The Second Amendment only guarantees the right to possess a single firearm; the law does not prevent defense or possession—just limits frequency of purchases.	The restriction imposes a meaningful constraint on the protected right; the Second Amendment includes the right to possess and acquire multiple firearms.
Whether the law is supported by historical tradition of firearm regulation	There is no historical analogue for categorical, recurring bans on multiple firearm acquisitions by law-abiding citizens.	Historical firearms regulations restricted dangerous groups, certain weapons, or imposed licensing, thus analogous restrictions exist.	No relevantly similar historical analogue supports California's law; most historical restrictions were narrower or did not meaningfully burden acquisition rights.
Application of precedent and standard under Bruen	Bruen requires government to show relevantly similar historical analogue; absent that, restriction is unconstitutional.	Bruen standard can be "nuanced" where modern concerns like bulk purchases differ from historical context; historical regulation should suffice.	The law is facially unconstitutional because the Bruen standard is not met: no relevant historical analogue exists.
Whether law’s exemptions or purpose (preventing trafficking) matter under the Second Amendment	Exemptions for certain groups or purposes do not cure the law's broad burden on most citizens.	Limiting sales to reduce illegal trafficking is a legitimate government interest that justifies the law.	Public safety purposes do not justify restrictions outside the bounds of historical firearm regulation under Second Amendment jurisprudence.

Key Cases Cited

N.Y. State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (Supreme Court clarified the historical tradition test for Second Amendment challenges)
District of Columbia v. Heller, 554 U.S. 570 (established the individual right to possess firearms for self-defense)
McDonald v. City of Chicago, 561 U.S. 742 (applied Second Amendment protections to states)
Heller v. District of Columbia (Heller III), 801 F.3d 264 (D.C. Cir. held that limitations on multiple firearm acquisitions restrict the right to keep arms)