The U.S. Court of Appeals for the Ninth Circuit affirmed a district court's summary judgment in favor of California in a facial Second Amendment challenge to the state's switchblade regulations. The case, *Knife Rights, Inc. v. Bonta*, was decided by a three-judge panel consisting of Circuit Judges Kim McLane Wardlaw, Ronald M. Gould, and Lucy H. Koh, with Judge Wardlaw writing the opinion.
The plaintiffs in the case included Knife Rights, Inc., an advocacy organization, along with several individuals who desire to keep and bear switchblades and two retailers of bladed weapons. They challenged California's switchblade regulations on Second Amendment grounds, arguing that the restrictions violated their constitutional right to keep and bear arms.
While California's switchblade regulations prohibit a wide range of conduct, the Ninth Circuit panel focused specifically on California Penal Code Section 21510(b), which prohibits the concealed carrying of switchblade knives in public. The court notably did not express any view on whether the regulation of any other conduct prohibited by California's broader switchblade regulations is constitutional, limiting its analysis to this specific provision.
The court applied the two-step framework established by the Supreme Court in *New York State Rifle and Pistol Association v. Bruen* (2022). Under this framework, courts must first determine whether the plain text of the Second Amendment covers the proposed conduct, and if so, proceed to examine whether the regulation is consistent with the nation's historical tradition of firearm regulation.
In applying the first step of the *Bruen* analysis, the Ninth Circuit panel assumed without deciding that the plain text of the Second Amendment covered the plaintiffs' proposed course of conduct. This means the court did not definitively rule on whether switchblades fall within the scope of Second Amendment protection, but proceeded to analyze the regulation under the assumption that they might.
Proceeding to the second step of the *Bruen* framework, the panel determined that California's prohibition on concealed carrying of switchblades in public is consistent with the nation's historical tradition of regulating dangerous and unusual weapons. This analysis requires courts to examine historical analogues and precedents to determine whether similar regulations existed at the time of the Second Amendment's ratification or during other relevant historical periods.
The case originated in the U.S. District Court for the Southern District of California, where District Judge James E. Simmons, Jr. presided over the initial proceedings. The district court had granted summary judgment in favor of California Attorney General Rob Bonta, finding that the state's switchblade regulations did not violate the Second Amendment.
Knife Rights, Inc. and the other plaintiffs appealed that decision to the Ninth Circuit, arguing that the district court erred in upholding the switchblade restrictions. The case was argued and submitted to the appeals court on Oct. 8, 2025, in Pasadena, California, before being decided on Jan. 30, 2026.
The Ninth Circuit's decision represents the latest development in ongoing litigation over state and local weapons regulations following the Supreme Court's decision in *Bruen*. That 2022 ruling established a new standard for evaluating Second Amendment challenges, requiring courts to assess whether modern regulations are consistent with historical traditions rather than applying intermediate scrutiny.
The ruling affects individuals and businesses in the Ninth Circuit's jurisdiction who sought to challenge California's switchblade regulations. For Knife Rights, Inc., a national organization that advocates for knife rights and has brought similar challenges in other jurisdictions, the decision represents a setback in their efforts to expand Second Amendment protections to cover edged weapons.
The decision also provides guidance for other courts evaluating Second Amendment challenges to knife regulations. By focusing on the concealed carry prohibition specifically and declining to address other aspects of California's switchblade laws, the Ninth Circuit left open the possibility that other provisions might face different constitutional analysis.
The case number for the appeal was 24-5536, with the underlying district court case designated as 3:23-cv-00474-JES-DDL. The decision was marked "FOR PUBLICATION," meaning it will serve as binding precedent within the Ninth Circuit.
While the panel affirmed the district court's summary judgment, it did so "on different grounds," though the specific nature of those different grounds was not detailed in the available portions of the opinion. This suggests the appeals court may have reached the same conclusion as the lower court but through different legal reasoning.
The ruling demonstrates the continued development of Second Amendment jurisprudence following *Bruen*, particularly as it applies to weapons other than firearms. Courts across the country are grappling with how to apply the Supreme Court's historical analysis framework to various state and local weapons regulations, making this decision part of a broader pattern of post-*Bruen* litigation.