A Federal Judge Halts California’s Confiscation of High-Capacity Magazines – National Review
In 2000, California banned the sale of firearm magazines that can hold more than ten rounds. Residents who already possessed such magazines were grandfathered in. Or at least that was the promise.
Recently, Californians approved Proposition 63, which would have required all grandfathered owners to surrender those magazines by July 1, 2017, or face up to a year in prison. Civil-rights groups challenged the confiscation in federal courts. With less than a day to spare, Judge Roger T. Benitez of the Southern District of California blocked the measure from going into effect. In his thoughtful opinion, he meticulously deconstructs every strawman erected by gun-control advocates, who can show no evidence that limiting magazine sizes will improve public safety. No doubt this decision will be appealed, but the higher courts should take note: Judge Benitez provided a clinic on how to scrutinize laws that restrict Second Amendments rights.
In District of Columbia v. Heller, the Supreme Court recognized that the Second Amendment protects an individual right to keep and bear arms. That right is not limited to guns; it extends also to the ammunition and magazines that make the gun operable. Californias law directly infringes on that right, by prohibiting law-abiding firearm owners from using their magazine of choice for self-defense. Following Heller, lower courts have held that the government can ban certain types of arms only if it demonstrates that doing so will reasonably protect public safety. Unfortunately, in the past, most judges simply rubber-stamp whatever evidence the state provides to justify gun-control measures, whether or not it fits with public safety.
Not Judge Benitez. He refused to defer to the attorney generals incomplete studies from unreliable sources about a homogenousmass of horrible crimes in jurisdictions near and far for which large capacity magazines were not the cause. With the precision of a scalpel, the court systemically sliced apart the governments unpersuasive efforts to justify the ban. For example, the attorney general had relied on a survey of shootings published by Mother Jones, a progressive magazine. Judge Benitez dismissed the publication, which has rarely been mentioned by any court as reliable evidence. Moreover, he added, it is fair to say that the magazine survey lacks some of the earmarks of a scientifically designed and unbiased collection of data.
What about the governments citation of a survey issued by the group Mayors Against Illegal Guns? Judge Benitez noted that this group, founded by former New York City mayor Michael Bloomberg, is apparently not a pro-gun rights organization. That is an understatement. More significantly, the court concluded, the survey of 92 mass shootings 82 of which were outside California does not demonstrate that the ban on possession of magazines holding any more than 10 rounds would reasonably help the state to achieve its public-safety goals. Of the ten shootings in California, eight were not known to involve high-capacity magazines, and two involved magazines that were probably illegal. For example, the Santa Monica shooter used high-capacity magazines that were likely shipped from outside California. Criminalizing possession of magazines holding any more than 10 rounds, the court reasoned, likely would not have provided additional protection from gun violence for citizens or police officers or prevented the crime. More important, even though millions of high-capacity magazine are owned nationwide, the mayors survey could identify only six mass-shooting incidents between 2009 and 2013 that employed them.
The governments expert witnesses fared no better. The court dismissed their evidence as little more than anecdotal accounts, collected by biased entities, on which educated surmises and tautological observations are framed. One professor said the ban on high-capacity magazines seems prudent, based only on what Judge Benitez labelled a complete absence of reliable studies done on formal data sets. Another professor justified the ban on large magazines by citing the need to force mass shooters to pause and reload ammunition. That argument, supported by zero data, is belied by common experience. The court noted that during mass shootings in Alexandria, Va., and Fort Hood, Texas, mass shooters were able to reload several times without difficulty; they were stopped only when confronted by another shooter. In any event, why stop at ten rounds? For example, New York sought to limit magazine sizes to seven rounds, because the average defensive gun use involves on average two rounds. Judge Benitez asked, somewhat rhetorically, why not then limit magazines to three rounds?
In other contexts, courts are perfectly comfortable second-guessing the governments need to promote public safety even concerning the rights of aliens outside the United States and in delicate matters of foreign affairs. For example, in recent litigation over the travel ban, federal courts have dismissed the executive branchs goal of protecting national security as a fraud. But with the Second Amendment, courts have regrettably treated the right to keep and bear arms as a second-class right and consistently accepted the governments interests as articles of blind faith.
Not so in Judge Benitezs courtroom. He explained that the phrase gun violence may not be invoked as a talismanic incantation to justify any exercise of state power. In any case, the measures in question would not deter crime. Criminals intent on violence would then equip themselves with multiple weapons, Benitez observed. Or, as Justice Stephen Breyer noted last year in an opinion striking down Texass abortion laws, determined wrongdoers, already ignoring existing statutes and safety measures, are unlikely to be convinced to adopt safe practices by a new overlay of regulations. (Of course, the right to keep and bear arms is framed in the Constitution; a right to privacy is not.) Criminals bent on breaking the law will break the law. Confiscation measures like Proposition 63 punish law-abiding citizens, limit their ability to defend themselves, and have at best a negligible impact on public safety.
On the same day that Judge Benitez issued his important decision, another federal judge in Sacramento reached the opposite result, allowing the confiscation measure to go into effect. The California attorney general will no doubt seek an emergency stay from the Ninth Circuit Court of Appeals to nullify Judge Benitezs decision. Second Amendment rights, alas, have not fared well in that court. Because of the urgency of this case, sooner or later an emergency petition may wind up on the desk of Justice Anthony Kennedy, who supervises appeals from California. Justice Kennedy joined the Heller decision in 2008 and two years later joined the follow-up case of McDonald v. City of Chicago. But since 2010, the Court has not heard arguments in any Second Amendment case.
Regrettably, last week the Supreme Court turned away another case from California that concerned the right to carry outside the home. Only Justice Clarence Thomas and his newest colleague, Justice Neil Gorsuch, disagreed: The Courts decision to deny certiorari in this case reflects a distressing trend: the treatment of the Second Amendment as a disfavored right, Thomas wrote. Over the last seven years, the justices have hesitated to expand gun rights beyond allowing law-abiding citizens to keep a firearm in the home. Proposition 63 is radically different from previous appeals: It attempts to take away what law-abiding citizens already have. Perhaps now that the fear of confiscation has come to fruition, five justices will intervene and ensure that Americans are not punished for exercising their constitutional rights.
READ MORE: Its Still a Mad, Mad California Californias Medicaid-Spending Crisis Californias Calexit Craziness
Josh Blackman is a constitutional-law professor at the South Texas College of Law in Houston, an adjunct scholar at the Cato Institute, and the author of Unraveled: Obamacare, Religious Liberty, and Executive Power.
Read more:
A Federal Judge Halts California's Confiscation of High-Capacity Magazines - National Review
- Federal Bills Introduced to Safeguard Second Amendment Rights During Government Shutdowns - NSSF | The Firearm Industry Trade Association - November 5th, 2025 [November 5th, 2025]
- Why the political arguments used by conservatives to twist the Second Amendment are a public fraud - Milwaukee Independent - November 5th, 2025 [November 5th, 2025]
- Save the Filibuster Save the Second Amendment - Gun Owners of America - November 5th, 2025 [November 5th, 2025]
- The Supreme Court Is More Interested in Second Amendment Cases Than Ever Before - The Trace - November 3rd, 2025 [November 3rd, 2025]
- SNL Weekend Update: Michael Che Says Government Still Aids Food Insecure Families Through Second Amendment After SNAP Cutoff - Deadline - November 3rd, 2025 [November 3rd, 2025]
- Supreme Court to weigh Second Amendment rights of cannabis users - inlander.com - November 3rd, 2025 [November 3rd, 2025]
- The Popular 3D-Printed Gun Globalizing the Second Amendment - Bloomberg - October 30th, 2025 [October 30th, 2025]
- The Future of the Second Amendment: A Nation Divided, Armed, and at a Crossroads - The Truth About Guns - October 30th, 2025 [October 30th, 2025]
- A warning to Florida public officials about the new open-carry law - Second Amendment Foundation - October 30th, 2025 [October 30th, 2025]
- Members Newsletter: Will SCOTUS Go Narrow in its New Second Amendment Cases? - The Reload - October 30th, 2025 [October 30th, 2025]
- I just took Everytowns online firearm training course - Second Amendment Foundation - October 28th, 2025 [October 28th, 2025]
- New Hampshire Bill Strengthening Second Amendment Rights on Public Property Advances - The Truth About Guns - October 26th, 2025 [October 26th, 2025]
- An Official Journal Of The NRA | Illegal Drugs and Second Amendment Rights - Americas 1st Freedom - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court Will Weigh Gun Restrictions for Drug Users - The New York Times - October 23rd, 2025 [October 23rd, 2025]
- The Right to Bear Technology: Americas Other Second Amendment - Andreessen Horowitz - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court adds another gun case to the docket, over drug use and the Second Amendment - MSNBC News - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will consider case on Second Amendment rights of drug users - Yahoo - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will decide if 'habitual drug users' lose their gun rights under Second Amendment - The Spokesman-Review - October 23rd, 2025 [October 23rd, 2025]
- Supreme Court will consider case on Second Amendment rights of drug users - Fox News - October 21st, 2025 [October 21st, 2025]
- Why an American raised in Rhodesia reveres the Second Amendment - Second Amendment Foundation - October 21st, 2025 [October 21st, 2025]
- In yet another move against gun ownership, California Democratic Governor Gavin Newsom recently signed Assembly Bill 1127 into law, triggering... - October 17th, 2025 [October 17th, 2025]
- Across the aisle: shootings, safety and the Second Amendment - The Muhlenberg Weekly - October 15th, 2025 [October 15th, 2025]
- Second Amendment auditors walking roads with rifle and body armor, Fla. cops say - Police1 - October 13th, 2025 [October 13th, 2025]
- The Second Amendment Holds More Weight Than Uncle Dicks Deer Stand - NSSF | The Firearm Industry Trade Association - October 11th, 2025 [October 11th, 2025]
- Supreme Court to hear Hawaii gun law case with Second Amendment implications - Baltimore Sun - October 11th, 2025 [October 11th, 2025]
- Our Next Debate: Would America Be Safer Without the Second Amendment? - The Free Press - October 9th, 2025 [October 9th, 2025]
- Fact Check Team: SCOTUS to hear Hawaii gun law case, potential impact on Second Amendment - The National Desk - October 9th, 2025 [October 9th, 2025]
- Second Amendment auditors walking Florida roads with AR-15 and body armor - Tampa Bay Times - October 9th, 2025 [October 9th, 2025]
- Fact Check Team: SCOTUS to hear Hawaii gun law case, potential impact on Second Amendment - KRCR - October 9th, 2025 [October 9th, 2025]
- Impac Mortgage : Discloses Execution of Second Amendment to Tax Benefits Preservation Rights Agreement and Execution of Amended and Restated Key... - October 9th, 2025 [October 9th, 2025]
- Supreme Court takes Second Amendment case challenging Hawaii gun law - Fox News - October 4th, 2025 [October 4th, 2025]
- Supreme Court takes case that could allow more guns in malls and restaurants - CNN - October 4th, 2025 [October 4th, 2025]
- Justices Take Up Second Amendment Case Over Hawaii's 'Affirmative Consent' Law - Law.com - October 4th, 2025 [October 4th, 2025]
- A different view on Second Amendment rights - thepress.net - October 4th, 2025 [October 4th, 2025]
- Second Amendment Roundup: Removal of Firearm Disabilities - inkl - October 2nd, 2025 [October 2nd, 2025]
- Pursuit Attractions and Hospitality, Inc. Enters into the Second Amendment to the Credit Agreement - MarketScreener - October 2nd, 2025 [October 2nd, 2025]
- Pass the CR, then fight with Truth , and the forgotten part of the second amendment. - Daily Kos - September 30th, 2025 [September 30th, 2025]
- Letters: What the Second Amendment really guarantees - NOLA.com - September 28th, 2025 [September 28th, 2025]
- The Correct Argument for the Second Amendment - The Stanford Review - September 25th, 2025 [September 25th, 2025]
- Letter to the Editor: Protect the Second Amendment - Bemidji Pioneer - September 25th, 2025 [September 25th, 2025]
- Supreme Court should revisit the Second Amendment - Wisconsin State Journal - September 21st, 2025 [September 21st, 2025]
- The Second Amendment Was Created to Put Down Slave Revolts - CounterPunch.org - September 19th, 2025 [September 19th, 2025]
- Charlie Kirks Shocking 2023 Gun Statement Goes VIRAL after Assassination | Defends Second Amendment - Oneindia - September 17th, 2025 [September 17th, 2025]
- Georgia Sheriff Calls Upon Citizens to Exercise Their Second Amendment Rights - Firearms News - September 17th, 2025 [September 17th, 2025]
- The Trump Administration's Half-Baked Plan to Disarm Transgender People Is Legally Bankrupt: Such a Gun Ban Is Not Authorized by Statute or Allowed by... - September 17th, 2025 [September 17th, 2025]
- Budget Committee Approves Ratification Bill on Second Amendment to EC-Bulgaria Financing Agreement under Recovery and Resilience Facility - - September 17th, 2025 [September 17th, 2025]
- Guns of Delusion: Who killed Charlie Kirk? America's Second Amendment obstinacy - The Times of India - September 13th, 2025 [September 13th, 2025]
- Charlie Kirks Murder Illustrates How the Second Amendment Is Swallowing the First - Slate - September 13th, 2025 [September 13th, 2025]
- Vaccines, the Second Amendment, and the Utah Supreme Court - Utah Public Radio - September 13th, 2025 [September 13th, 2025]
- Florida Court Strikes Down Open Carry Ban, Aligning Firearm Laws with Second Amendment - Hoodline - September 13th, 2025 [September 13th, 2025]
- Charlie Kirk's pro-Second Amendment stance revisited after shooting death - Daily Express US - September 13th, 2025 [September 13th, 2025]
- Florida touts big win for Second Amendment after court throws out open carry ban - Washington Examiner - September 13th, 2025 [September 13th, 2025]
- Second Amendment activists in shock as Charlie Kirk shot instead of just schoolchildren - The Beaverton - September 13th, 2025 [September 13th, 2025]
- Fact Check: Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Yahoo News UK - September 11th, 2025 [September 11th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - The Northwest Florida Daily News - September 11th, 2025 [September 11th, 2025]
- Fact Check: Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Yahoo News Canada - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk once said some gun deaths 'worth it' in order to have Second Amendment - Snopes - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk said "some gun deaths" were an acceptable cost for having Second Amendment gun rights - Daily Kos - September 11th, 2025 [September 11th, 2025]
- Medical Marijuana and the Second Amendment: Eleventh Circuit Revives Second Amendment Challenge to Federal Ban on Gun Ownership for Drug Users - JD... - September 11th, 2025 [September 11th, 2025]
- Charlie Kirks Pro-Gun, Second Amendment Comments Resurface After Fatal Shooting at UVU - Times Now - September 11th, 2025 [September 11th, 2025]
- Reader says protect Second Amendment rights, but reduce access to some firearms - San Antonio Express-News - September 11th, 2025 [September 11th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - Lakeland Ledger - September 11th, 2025 [September 11th, 2025]
- Charlie Kirk, shot dead in Utah, once said gun deaths are 'worth it' to save Second Amendment - Firstpost - September 11th, 2025 [September 11th, 2025]
- Florida will have a Second Amendment sales tax holiday. Here's what to know - Pensacola News Journal - September 9th, 2025 [September 9th, 2025]
- DeSantis announces 'Second Amendment' tax holiday, renews push for open carry of guns - yahoo.com - September 9th, 2025 [September 9th, 2025]
- Florida Second Amendment Sales Tax Holiday begins, runs through end of the year - Floridas Voice - September 9th, 2025 [September 9th, 2025]
- Marylands Handgun Roster Board: a rubber stamp or assault on Second Amendment? - Baltimore Sun - September 6th, 2025 [September 6th, 2025]
- Tennessee joins other states on Second Amendment SCOTUS brief - WKRN News 2 - September 6th, 2025 [September 6th, 2025]
- Opinion: Bill 36-0144 Is an Unconstitutional and Racist Attack on the Second Amendment - The Virgin Islands Consortium - September 6th, 2025 [September 6th, 2025]
- Letter to the Editor: Americas Deadliest LoopholeThe Case Against the Second Amendment - Peachtree City Citizen - September 6th, 2025 [September 6th, 2025]
- Congressional Democrats Try to Stop AG Bondi from Restoring Ex-Offenders Second Amendment Rights - Cato Institute - September 5th, 2025 [September 5th, 2025]
- Understanding the Second Amendment commas and all - thepress.net - September 5th, 2025 [September 5th, 2025]
- In Louisiana, gun sales are promoted with Second Amendment tax break - Shreveport Times - September 3rd, 2025 [September 3rd, 2025]
- In Louisiana, gun sales are promoted with Second Amendment tax break - yahoo.com - September 3rd, 2025 [September 3rd, 2025]
- Cabinet Asks Parliament to Ratify Second Amendment to Recovery, Resilience Facility Financing Agreement with EC - - September 3rd, 2025 [September 3rd, 2025]
- Hunters get tax break during Louisianas Second Amendment Sales Tax Holiday Sept. 57 - Unfiltered with Kiran - September 3rd, 2025 [September 3rd, 2025]
- Analysis: The Latest on Weed, Dangerousness, and the Second Amendment [Member Exclusive] - The Reload - September 1st, 2025 [September 1st, 2025]
- Second Amendment Sales Tax Holiday recognized this weekend - WAPT - August 29th, 2025 [August 29th, 2025]
- Mississippis Second Amendment Sales Tax Holiday set for this weekend - supertalk.fm - August 29th, 2025 [August 29th, 2025]
- Minneapolis shooting: Who is Brandon Herrera? Second Amendment activist named in now-deleted video of att - The Times of India - August 29th, 2025 [August 29th, 2025]