Ninth Circuit Strikes Down California’s Background Check Requirement for Ammo Purchases in NRA Backed Case

by
posted on July 29, 2025
** When you buy products through the links on our site, we may earn a commission that supports NRA's mission to protect, preserve and defend the Second Amendment. **
NRA ILA Lede

The Ninth Circuit Court of Appeals ruled that California’s law requiring a background check for each ammunition purchase violates the Second Amendment in Rhode v. Bonta—a case backed by the National Rifle Association and California Rifle and Pistol Association.

The Ninth Circuit applied the text-and-history test set forth in the NRA’s landmark Supreme Court victory, NYSRPA v. Bruen.

“The Ninth Circuit has ruled California’s ammunition law violates the Second Amendment and is unconstitutional,” said NRA Executive Vice President and Chief Executive Officer Doug Hamlin. “This is just one example of the NRA-backed cases in which we fight for the constitutionally protected rights of NRA members and law-abiding gun owners in California.”

First, the Ninth Circuit determined that the background check requirement regulates conduct covered by the Second Amendment’s plain text, because it meaningfully constrains the right to keep operable arms.

Next, the court concluded that the background check regime is inconsistent with America’s historical tradition of firearm regulation, because no such law nor analogous law was ever enacted before the twentieth century.

Finally, the Ninth Circuit considered language from a footnote in Bruen in which the Supreme Court indicated that some shall-issue carry regimes are likely constitutional. The Ninth Circuit determined that this language did not apply to background checks for ammunition purchases—which are distinct from licensing laws for handgun carry—and further, that California’s ammunition background check regime is more burdensome than a typical shall-issue carry regime because California’s law requires a background check before every ammunition purchase regardless of when the last purchase occurred.

The Ninth Circuit thus held that California’s background check regime violates the Second Amendment and affirmed the district court’s order granting a permanent injunction against the law’s enforcement.

“This is a win for law-abiding gun owners who have had their freedom infringed upon by California’s unconstitutional ammo law,” said NRA-ILA Executive Director John Commerford. “Instead of harassing honest, law-aiding gun owners--like six-time Olympic medal winner and former NRA Director Kim Rhode--the state should put its resources into catching and prosecuting real criminals and putting an end to the lawlessness on its streets.”

The Ninth Circuit got this right. If California chooses to keep defending this unconstitutional law, NRA is fully committed to pursuing this case to the end, up to and including the steps of the U.S. Supreme Court.

Latest

LEDEW H2026 08 Membershunt George Perryman Five Generations Strong
LEDEW H2026 08 Membershunt George Perryman Five Generations Strong

The Fox Model B That Keeps on Hunting

Do you have a favorite old firearm that just won't quit? Then this story, from George Perryman of Lexington, N.C., is for you.

Hardware Review: Marlin Trapper Model 1894 10mm Auto

Whenever a gunmaker introduces a new handgun or a carbine chambered in a pistol round, one of the social media comments to immediately follow will be: “Are you going to make it in 10mm?” Marlin Firearms has answered this question with a resounding "Yes!"

Top 5 Budget Hunting Riflescopes

There are few joys as great as a shooting with a high-end, premium optic, with its crystal-clear image from premium lenses. There are also the realities of a modest hunting budget, and staying within your financial means makes for a happier home. Curious about the latter? Check out this comprehensive list.

Range Review: DIY Howa Superlite 6.5 Creedmoor

Working with Brownells and Stocky's you can assemble this lightweight bolt gun just the way you want it!

Federal is the Official Ammunition of the Minnesota Wild

Federal Ammunition has announced it will be the official ammunition of the Minnesota Wild for the 2026-27 season. This agreement with the hometown NHL franchise is historic as it is the first partnership with a major league professional sports team in Federal's 104-year history.

#SundayGunday: CVA Cascade Rimfire

On this week's #SundayGunday, we’re checking out the Cascade Rimfire, from CVA, a lightweight rimfire absolutely perfect for tackling squirrel season. Chambered in .22 Long Rifle, the Cascade Rimfire sports an 18-inch barrel that hits the perfect sweet spot between easy accuracy and maneuverability. Learn more about it in this exclusive video.

Interests



Get the best of American Hunter delivered to your inbox.