A recent decision this month out of California has sent shockwaves through the gun rights community — and for good reason. In Boland v. Bonta, U.S. District Judge Cormac J. Carney of the Central District of California struck down the core of the state’s notorious Unsafe Handgun Act, a law that for years has kept most modern handguns off the shelves for ordinary Californians. The decision, which granted a preliminary injunction against California’s so‑called “roster” requirements, represents one of the most significant post‑Bruen victories for the Second Amendment to date — and it could have serious implications for Massachusetts, where similar restrictions (infringements) remain firmly in place.
California’s Handgun Roster: A De Facto Ban on New Firearms
For years, California officials have boasted that their handgun roster is a “safety” measure. But in practice, it’s been a slow‑motion, roving ban. To qualify for sale, new semi‑automatic handguns must have:
- a loaded chamber indicator (LCI),
- a magazine disconnect mechanism (MDM), and
- the ability to microstamp identifying marks on spent casings.
The problem? Not a single manufacturer has been able to meet the microstamping requirement in real‑world production. The result is that no new handgun models have been added to the roster since 2013. Californians have been locked out of purchasing modern, state‑of‑the‑art firearms for self‑defense — while the rest of America has moved forward with safer, more reliable designs.
The Court’s Ruling: Second Amendment Means Modern Arms
Judge Carney’s decision pulls no punches. He found that the state’s mandates likely violate the Second Amendment, applying the Supreme Court’s Bruen test, which requires gun restrictions to be consistent with the historical tradition of firearm regulation.
The ruling highlighted several key points:
- The handgun roster deprives Californians of access to modern firearms, effectively freezing the market in place.
- The microstamping mandate is unworkable, meaning citizens are forced to buy older, less safe, and less reliable models.
- Under Bruen, the government must point to a historical analogue for such sweeping restrictions — and California couldn’t.
In short: Californians, like all Americans, have a constitutional right to own current, effective tools for self‑defense — not just outdated relics.
Why This Matters for Massachusetts
While the ruling is a huge win in California, it may echo loudly here in Massachusetts, where the Commonwealth has its own handgun roster and subjective “suitability” requirements that mirror much of California’s approach.
- Massachusetts Handgun Roster: Like California, Massachusetts maintains a list of “approved” firearms, restricting which handguns can be sold. Many popular and modern models are unavailable to Massachusetts residents.
- Attorney General’s “Consumer Protection” Regs: The Massachusetts AG has long used consumer protection powers to impose added restrictions on handguns, layering more red tape on top of the roster.
- Suitability Standards: In addition to the roster, Massachusetts licensing authorities still apply discretionary “suitability” requirements, which have already been called into constitutional question in recent municipal court decisions post‑Bruen.
If the Ninth Circuit upholds Judge Carney’s injunction, it could embolden challenges in Massachusetts. Litigants could argue that the Commonwealth’s roster likewise locks residents into outdated firearms and deprives them of modern self‑defense options, with no grounding in historical tradition.
The Bigger Picture: A Domino Effect After Bruen
This case is part of a larger trend: courts across the country are beginning to strike down outdated “may‑issue” and roster‑style gun laws that were once considered untouchable. From New York to New Jersey, and now California, Bruen has given citizens the tools to fight back.
For Massachusetts gun owners, the California decision offers a roadmap for litigation:
- Challenge the handgun roster as an unconstitutional infringement on the right to acquire modern arms.
- Target discretionary suitability standards as incompatible with Bruen’s rejection of “may issue” licensing.
- Press for preliminary injunctions to halt enforcement while challenges are pending.
MA GUN LAWYER 
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