Virgina Duncan v Bonta Challenge To California's Large Capacity Mag Ban

Second Amendment case challenging California's ban on large-capacity magazines (LCMs), defined as those holding more than 10 rounds. The Ninth Circuit again heard the case en banc and, in a 7–4 decision on March 20, 2025, once more upheld California's ban. Using the Bruen historical analysis framework, the majority concluded that large-capacity magazines are not considered "arms" protected by the plain text of the Second Amendment. It further reasoned that even if they were, the ban is consistent with the nation's historical tradition of firearm regulation by citing Founding-era gunpowder storage laws as a historical analogue. The dissenting judges strongly disagreed, arguing the magazines are "arms" in common use for self-defense and that no historical analogue supports the ban.