Policy Text
TRAINING BULLETIN
Issue: 24-37 DATE: November 12, 2024
California Penal Code 22210 Injunction
This training bulletin provides an overview and analysis of the Fouts v. Bonta (2024)
case, focusing on the possession of “Billy Clubs” as it pertains to Penal Code 22210. The
court ruled that possession of a “Billy Club” is constitutionally protected under the Second
Amendment.
California Penal Code 22210: Any person who manufactures or causes to be
manufactured, imports into the state, keeps for sale or offers or exposes for sale, or who
gives, lends, or possesses any leaded cane, or any instrument or weapon of the kind
commonly known as a billy, blackjack, sandbag, sandclub, sap, or slungshot, is
punishable by imprisonment in a county jail not exceeding one year or imprisonment
pursuant to subdivision (h) of Section 1170.
Baton-like weapons, such as “Billy Clubs,” have been outlawed for civilians in some form
in California since 1923.