Federal Court Strikes Down California Ammunition Checks Over 11% Rejection Rate and Unconstitutional Burdens

A federal appeals court has invalidated California’s 2016 voter-approved law requiring background checks for ammunition purchases, ruling it unconstitutional under the Second Amendment. The 9th U.S. Circuit Court of Appeals affirmed a lower court’s 2024 decision, holding that the law “meaningfully constrains” the right to bear arms by forcing gun owners to undergo repeated background checks for bullets [1]. The law, which took effect in 2019, mandated a $1 or $19 fee per ammunition purchase, depending on eligibility, and was criticized for disproportionately affecting legal gun owners who struggled to access bullets due to database limitations [2].

The ruling centered on the Supreme Court’s 2022 Bruen decision, which requires gun laws to align with historical firearm regulations. Judge Sandra Segal Ikuta, writing for the majority, argued that California failed to demonstrate the law’s consistency with historical precedents, a key requirement under Bruen [3]. The court also noted that the law’s application could extend beyond California’s intent, potentially invalidating any modern ammunition restrictions lacking historical analogs.

Democratic Gov. Gavin Newsom and the California Department of Justice condemned the decision, calling the law a “common-sense, lifesaving” measure to prevent prohibited individuals from obtaining bullets. The department cited a 2024 state report showing the law blocked 200 ammunition sales to ineligible buyers [6]. However, gun rights advocates, including the California Rifle & Pistol Association (CRPA), framed the law as “absurdly restrictive,” emphasizing that firearms are ineffective without ammunition [4]. CRPA President Chuck Michel hailed the ruling as a victory against “overreaching government gun control.”

The case highlighted tensions over enforcement challenges. Critics noted the state’s automated background check system rejected 11% of applicants in 2023, complicating legal purchases for out-of-state residents and owners of older guns. Local gun shop owner John Parkin argued the law was “written to make California gun owners angry,” offering no clear safety benefits while creating logistical hurdles [5].

The decision aligns with broader post-Bruen legal trends. Since 2022, over 2,000 gun law cases have been filed, with 24 Republican-led states and gun rights groups challenging regulations. Judge Jay Bybee, the dissenting voice, argued the law imposed minimal burdens—a $1 fee and under a minute of delay—and did not constitute “heavy-handed regulations” [5].

California’s response remains uncertain. While the law is now permanently unenforceable, officials expressed intent to explore legal options. The ruling underscores the Supreme Court’s narrowing interpretation of the Second Amendment, complicating efforts to enact modern gun control measures. Analysts suggest the outcome will influence future litigation, particularly as states balance historical context with contemporary public safety concerns.

Sources:

[1] [CalMatters](https://calmatters.org/justice/2025/07/gun-law-ammunition-background-check/)

[2] [AP News](https://apnews.com/article/california-ammunition-gun-background-checks-ed7f0b0f7eede45aaed49df8430e2583)

[3] [The Guardian](https://www.theguardian.com/us-news/2025/jul/24/california-background-checks-ammunition)

[4] [Reuters](https://www.reuters.com/legal/government/california-ammunition-background-checks-declared-unconstitutional-by-us-appeals-2025-07-24/)

[5] [The Guardian](https://www.theguardian.com/us-news/2025/jul/24/california-background-checks-ammunition)

[6] [AP News](https://apnews.com/article/california-ammunition-gun-background-checks-ed7f0b0f7eede45aaed49df8430e2583)