Ninth Circuit Upholds California Switchblade Ban, Underscoring Continued Resistance to Bruen 

            In another troubling signal that lower courts remain willing to narrow constitutional protections post-Bruen, the U.S. Court of Appeals for the Ninth Circuit has ruled that states may continue to criminalize the carry of certain pocketknives. In a unanimous decision issued Friday, a three-judge Ninth Circuit panel upheld California’s restrictions on switchblades—at least as they apply to concealed carry. The ruling came in Knife Rights v. Bonta, a Second Amendment challenge brought by the knife-rights advocacy group Knife Rights along with California residents and retailers.

Writing for the panel, Judge Kim Wardlaw emphasized the narrowness of the ruling. “Today, we decide only that Plaintiffs’ facial challenge to California’s switchblade regulations fails,” Wardlaw wrote. “Our Nation’s historical tradition supports California’s prohibition against the concealed carry of switchblades.”

The decision preserves California’s status as one of the few remaining states to heavily restrict automatic knives—and marks yet another instance where an appellate court has upheld a categorical weapons restriction despite the Supreme Court’s clear guidance in New York State Rifle & Pistol Association v. Bruen.

As we previously covered in our 2 If By Sea Tactical analysis of the Ninth Circuit’s open-carry ruling, the court continues to apply Bruen selectively—often carving laws into smaller pieces to save them from full constitutional scrutiny. In this case, the panel avoided ruling on California’s broader prohibitions, including bans on possession in vehicles, public carry, or sale. Instead, it focused solely on concealed carry, effectively rewriting the statute for purposes of judicial review.

“We need not and do not express any view on whether the regulation of any of the other conduct prohibited by California’s switchblade regulations is constitutional,” Wardlaw wrote. That approach allowed the panel to accept nineteenth-century analogues involving Bowie knives, daggers, and clubs—historical comparisons the district court had previously rejected. Citing United States v. Rahimi, the panel argued that states need not produce a “historical twin” to justify modern restrictions, warning against reading Bruen too narrowly.

Knife Rights strongly criticized the ruling, accusing the panel of inventing “a narrower, imaginary version” of California’s law to avoid striking it down. “This decision conflicts with Supreme Court precedent and rests on a legal fiction,” the group said. “We are evaluating all options, including further review.” The case highlights an ongoing problem: while Bruen set a clear standard, some lower courts continue to resist its full application—especially when it comes to arms beyond firearms.

Although this case centers on California law, its implications stretch far beyond the Golden State. The Ninth Circuit’s reasoning may be cited by other courts seeking to uphold weapon bans through selective historical framing, even when those bans criminalize common, lawfully owned tools. That trend reinforces a hard truth: Second Amendment rights remain under pressure—not just from legislatures, but from courts willing to reinterpret Supreme Court precedent.

At 2 If By Sea Tactical, we’ve said it before and we’ll keep saying it: Bruen was not the end of the fight. As long as lower courts continue to defy or dilute Supreme Court guidance, vigilance is essential. As Southern Minnesota’s premier Indoor Range and Store, we support the full spectrum of lawful self-defense tools. That includes quality knives—yes, including Krate OTF (Out the Front) knives, which we proudly carry for customers who value reliable, American-made everyday carry options. Rights that are exercised are harder to erase. Train. Carry responsibly. Stay informed. And when courts try to whittle away constitutional protections one ruling at a time, remember: freedom doesn’t defend itself.

Here at 2 If By Sea Tactical we strive to bring you the best experience in the firearms world.  As we continue to grow the media arm of 2 If By Sea, make sure you keep tuning in to our Youtube and Rumble channels and right here at “The Patriot’s Almanac” to stay informed on the latest happenings in the firearm world! But we are not lawyers, so this isn't legal guidance.

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