A liberal federal appellate court previously ruled that California’s version of a signature provision of federal legislation being pushed by two Democrat senators was unconstitutional.
In an April 16 release, Democratic Virginia Sens. Tim Kaine and Mark Warner said they had introduced the “Virginia Plan to Reduce Gun Violence Act,” also known as S 4339, highlighting a “one gun a month” restriction on handgun purchases that Virginia first enacted in 1993 and reimposed in 2020. However, on June 11, 2025, a three-judge panel from the United States Court of Appeals for the Ninth Circuit, consisting of United States Circuit Judges Bridget S. Bade, Danielle J. Forrest and John Owens, struck down California’s version of the “one gun a month” limit in a 3-0 ruling.
“California’s law is facially unconstitutional because possession of multiple firearms and the ability to acquire firearms through purchase without meaningful constraints are protected by the Second Amendment and California’s law is not supported by our nation’s tradition of firearms regulation,” the opinion, written by Forrest, said.
Owens concurred with the decision, noting that while their decision struck down the rationing, “it does not address other means of restricting bulk and straw purchasing of firearms, which our nation’s tradition of firearm regulation may support.”
Bade and Forrest were appointed to the bench during President Donald Trump’s first term, while Owens was an appointee of former President Barack Obama. While the margin between Republican and Democratic appointees narrowed during Trump’s first administration, Democratic appointees still held a majority on the court, Daily Journal reported.
Kaine and Warner did not immediately respond to requests for comment from the Daily Caller News Foundation when asked about the rulings from the Ninth Circuit, which has a long-standing reputation as being a left-leaning federal appellate court.
The Supreme Court has overturned almost four out of every five decisions the Ninth Circuit has issued since 2007, according to the Pacific Research Institute, with the high court reversing 94% of the circuit’s rulings in the term ending in June 2021. The National Rifle Association did not immediately comment on if it planned to launch legal challenges to Virginia’s “one gun a month” provision when contacted by the DCNF.
The Firearms Policy Coalition (FPC) initially filed suit against California over the restriction in December 2020, with a complaint filed in the United States District Court for the District of Southern California. United States Senior District Judge William Q. Hayes granted summary judgment in favor of the plaintiffs on March 11, 2024.
Only four states currently have laws that restrict the quantity of firearms purchases in effect. Virginia enacted “one gun a month” in 1993, saw it repealed in 2012, but it was reimposed in 2020, while Maryland enacted its version in 1996 and New Jersey enacted a similar law in 2009. Connecticut has a limit of three handguns per month enacted in 2023.
Besides California, one state and Washington, D.C., previously had similar restrictions, according to the Giffords Law Center. South Carolina’s was in force from 1975 to 2004 before the state Legislature repealed it, while the version in the District was struck down in 2015 by the United States Court of Appeals for the District of Columbia Circuit.
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