Member Alert: New Handguns Added to California Roster Pursuant to Boland v. Bonta
For over a decade, California’s Unsafe Handgun Act froze the state’s handgun roster in place. The microstamping mandate, which took effect in 2013, made it virtually impossible for manufacturers to add new semiautomatic pistol models to the Roster of Certified Handguns. The roster shrank year after year. Californians were locked out of the same modern, reliable handguns available to law-abiding citizens in every other state.
CRPA refused to accept that. And because of your support, the roster is growing again.
25 New Models Added Today
Today, September 3, 2026, the California Department of Justice added 25 new semiautomatic handgun models to the Roster of Certified Handguns pursuant to the court’s order in Boland v. Bonta, CRPA’s federal lawsuit challenging the Unsafe Handgun Act.
Smith & Wesson (20 models):
· M&P 10mm M2.0 (4.6” and 5.6” barrels, optics ready)
· M&P9 Shield Plus OR
· Shield X 9mm (4 configurations)
· Bodyguard 2.0 .380 AUTO (7 configurations)
· S&W BG 2.0 TLCI MS TS RFX1
· PC M&P9 M2.0 Compact Carry Comp
· PC M&P9 M2.0 AF Carry Comp
· PC Shield X CC (2 configurations)
· PC Bodyguard 2.0 CC (3 configurations)
SIG Sauer (3 models):
· 211F-9-GT5-CA (5.0” barrel)
· 211CA-9-GT4-CA (4.2” barrel)
· 365XCA-9-COMP-MS-SL-CA (3.1” barrel)
Biofire (2 models):
· Smart Gun (Dark Terra)
· Smart Gun (Orbital White)
Not a single one of these handguns would be available to California consumers without CRPA’s lawsuit. The full list is available at oag.ca.gov/firearms/certified-handguns/recently-added.
Boland v. Bonta: Where Things Stand
In March 2023, Judge Cormac Carney of the U.S. District Court for the Central District of California granted CRPA’s motion for a preliminary injunction, finding that the Unsafe Handgun Act’s microstamping, chamber load indicator, and magazine disconnect requirements likely violate the Second Amendment under the U.S. Supreme Court’s framework in Boland v. Bonta. The court held that these requirements “generally prohibit Californians from acquiring state-of-the-art handguns” that are protected arms under the Second Amendment, and that the State failed to identify any historical tradition justifying those restrictions.
The State appealed. The Ninth Circuit partially stayed the injunction, reinstating the chamber load indicator and magazine disconnect requirements while the appeal proceeds, but left the microstamping injunction in place. That injunction is the reason new semiautomatic pistols are reaching the California roster for the first time in over a decade.
Following oral argument in August 2023, the Ninth Circuit held the case pending its en banc decision in Duncan v. Bonta. After Duncan was decided in March 2025, the court ordered supplemental briefing, which both sides completed in spring 2025. The appeal is now fully briefed and awaiting decision before the same 11-judge en banc panel.
The Fight Is Far From Over
The fight is far from over. The microstamping injunction that opened the door for these new roster additions remains in effect only because of this litigation. If CRPA were not actively prosecuting Boland v. Bonta, the injunction could be dissolved and the roster would once again be frozen.
CRPA continues to press for full invalidation of the Unsafe Handgun Act’s unconstitutional restrictions, including the chamber load indicator and magazine disconnect requirements that the Ninth Circuit temporarily reinstated. These requirements continue to block additional handgun models from reaching California consumers. A favorable ruling from the en banc panel would be a generational victory for California gun owners, striking down all three requirements and restoring meaningful access to modern, reliable handguns protected by the Second Amendment.
Your Support Makes This Possible
Every new handgun on that roster exists because CRPA had the resources to take this fight to federal court and sustain it for years. Litigation of this magnitude costs hundreds of thousands of dollars. Your donations fund the attorneys, experts, and briefing that make victories like Boland possible.