Case Explained: KNIFE RIGHTS, INC., ET AL. V. BONTA

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-16

Docket: 3:23-cv-00474-

The ninth-circuit denied petitions for panel rehearing and rehearing en banc, thereby affirming the district court’s summary judgment in favor of California regarding a facial Second Amendment challenge to the state’s switchblade regulations. The panel held that because Plaintiffs elected to pursue a facial challenge, they bore the burden under *United States v. Salerno* and *New York State Rifle & Pistol Ass’n, Inc. v. Bruen* to establish that no set of circumstances exists under which California’s switchblade regulations would be valid. The court concluded this burden was not met because it found that California constitutionally prohibits the concealed carry of switchblade knives, a restriction supported by the nation’s historical tradition of arms regulation. Consequently, the panel ruled narrowly that the existence of at least one constitutional application (the ban on concealed carry) was sufficient to defeat the facial challenge, without addressing whether bans on open carry or other provisions were constitutional. The practical consequence is that the panel’s decision stands as binding precedent within the Ninth Circuit, leaving Plaintiffs free to bring future as-applied challenges specifically targeting the regulation of open carry or other applications of the statute, while the current total ban remains in effect for the time being.

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