Nguyen v. Bonta
- Proceeding
- district
- Area
- civil
- On appeal
- Nguyen v. Bonta (2025-06-20) — affirmed — the Ninth Circuit's later ruling on this docket
- Panel
- William Q. Hayes (author)
Analysis
The court was presented with cross-motions for summary judgment challenging California's handgun purchase limits under the Second Amendment. The court ordered the parties to file supplemental briefing on how the Supreme Court's decision in New York Rifle & Pistol Assn., Inc. v. Bruen affects the legal standard and the resolution of the motions.
| What the court decided | The model |
|---|---|
Ordering supplemental briefing on the impact of New York Rifle & Pistol Assn., Inc. v. Bruen on the pending motions for summary judgment“The Court finds that additional briefing regarding the effect of Bruen on the resolution of the parties’ Motions for Summary Judgment is appropriate.” | agree with court The court correctly identified that the Supreme Court's decision in Bruen, issued one week prior to this order, fundamentally altered the analytical framework for Second Amendment challenges. Because the parties had briefed their motions based on the pre-Bruen 'two-step framework' (which Bruen effectively rejected in favor of a historical tradition test), the court was procedurally correct to pause the summary judgment process and request supplemental briefing to ensure the legal standard applied was current and accurate. |
The order itself: sound — The order is a procedural directive rather than a substantive ruling on the merits. It is 'sound' because it correctly identifies that a major change in controlling Supreme Court precedent (Bruen) occurred after the parties filed their initial summary judgment briefs. The court's decision to require supplemental briefing is the standard and appropriate judicial response to ensure the case is decided under the correct legal standard.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MICHELLE NGUYEN, an individual; Case No. 3:20-cv-02470-WQH-MDD 12 DOMINIC BOGUSKI, an individual; JAY MEDINA, an individual; FRANK 13 COLLETTI, an individual; JOHN ORDER PHILLIPS, an individual; PWGG, L.P., 14 a California Limited Partnership; DARIN PRINCE, an individual; 15 NORTH COUNTY SHOOTING CENTER, INC., a California 16 Corporation; FIREARMS POLICY COALITION, INC.; SAN DIEGO 17 COUNTY GUN OWNERS PAC; and SECOND AMENDMENT 18 FOUNDATION, 19 Plaintiffs, 20 v. 21 ROB BONTA, in his official capacity as Attorney General of California; and 22 LUIS LOPEZ, Director of the Attorney General’s Department of Justice Bureau 23 of Firearms, 24 Defendants. 25 26 HAYES, Judge: 27 On December 18, 2020, Plaintiffs initiated this action by filing a Complaint 28 challenging the enforcement of California Penal Code Section 27535, which restricts ] || the purchase of more than one handgun or semiautomatic centerfire rifle by a single 2 || person within a thirty-day period. (ECF No. 1). Plaintiffs bring two claims against 3 || Defendants pursuant to 42 U.S.C. § 1983 for violation of Plaintiffs’ rights under the 4 || Second and Fourteenth Amendments. 5 On April 8, 2022, Plaintiffs and Defendants filed respective Motions for 6 || Summary Judgment. (ECF Nos. 23, 29). Both motions contend that the Court should 7 || apply District of Columbia vy. Heller, 554 U.S. 570 (2008) and the “two-step 8 || framework” articulated by the Court of Appeals in adjudicating Plaintiffs’ Second 9 || Amendment claim. (See ECF Nos. 23-1 at 15-17, ECF No. 29 at 20). 10 On June 23, 2022, the United States Supreme Court issued New York Rifle & 11 || Pistol Assn., Inc. v. Bruen, 597 U.S. ___, 2022 WL 2251305 (2022). The Court finds 12 || that additional briefing regarding the effect of Bruen on the resolution of the parties’ 13 || Motions for Summary Judgment is appropriate. 14 IT IS HEREBY ORDERED that Plaintiffs and Defendants shall each file a 15 || supplemental brief addressing the following questions: 16 1) What standard applies to Plaintiffs’ Second Amendment claim after Bruen? 17 2) How does that standard apply to resolve the Motions for Summary 18 Judgment (ECF Nos. 23, 29)? 19 || The parties’ supplemental briefs are due on or before July 29, 2022, and are not to 20 || exceed twenty (20) pages in length. On the same date the parties may file any 21 || evidence not already presented to the Court in support of the supplemental briefs. 22 IT IS FURTHER ORDERED that on or before August 12, 2022, Plaintiffs and 23 || Defendants may each file a response to the opposing parties’ supplemental brief, not 24 || to exceed ten (10) pages in length. 95 Dated: June 30, 2022 Box Lg 2. A 2 6 Hon. William Q. Hayes United States District Court 27 28