Under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), when the Second Amendment’s plain text covers an individual’s conduct, the Constitution presumptively protects that conduct and the government must justify its regulation by demonstrating consistency with the Nation’s historical tradition of firearm regulation. The plain text covers the acquisition of arms. Heller and Bruen both recognize that the right to keep and bear arms necessarily includes the right to acquire them. Glock and Glock-pattern pistols are among the most popular handguns in the United States and are therefore arms “in common use” for lawful purposes, including self-defense. AB 1127 (Cal. Penal Code § 27595) prohibits licensed dealers from selling or transferring these common handguns on the theory that their cruciform trigger-bar design makes them more readily convertible to fully automatic fire with an illegal auto-sear. This is a ban on the arm itself, not a regulation of the auto-sear. There is no historical tradition from the founding era or Reconstruction of prohibiting the commercial sale of an entire class of common semi-automatic handguns because they could be illegally modified. The government may regulate or prohibit the auto-sear; it may not ban the protected arm on the basis of potential criminal misuse of a separate, already-illegal part. The restriction therefore fails Bruen Step Two.

Portable note — New Jersey conversion-device possession is not this statute.

P.L.2025, c.363 (A4974 1R, approved January 20, 2026) is live New Jersey law, not the withdrawn 2026 A-3595 refile. It defines a machine-gun conversion device and amends N.J.S. 2C:39-3(l): knowing possession of a bump stock, trigger crank, or conversion device when the person is not in possession of a firearm to which the device may be affixed is a third-degree crime, consecutive to certain N.J.S. 2C:39-5 counts. Manufacture, transport, or sale of the device is separately criminalized. That is a device count. It is not Cal. Penal Code § 27595, and it is not a ban on selling a Glock-pattern host pistol because the pistol could later accept a switch. Counsel should not charge-spot 2C:39-3(l) as an AB 1127 twin. Confirm compiled N.J.S. 2C:39-1 lettering before filing: chapters 363 and 255 both added a subsection (oo), eight days apart.

California Penal Code § 27595 (added by AB 1127, effective July 1, 2026) prohibits licensed firearms dealers from selling, offering for sale, exchanging, giving, transferring, or delivering any “semiautomatic machinegun-convertible pistol.” The statutory definition is written to capture pistols with cruciform trigger bars — the design used by virtually every Glock and the large majority of Glock-pattern striker-fired handguns currently in common use. This is a commercial-sale ban on arms that are in common use for self-defense. It is not a ban on machineguns, nor is it a regulation of auto-sears (already illegal under both state and federal law). It is a ban on the handgun itself, justified solely by the possibility that a criminal could later install an illegal conversion device. Bruen Step One is straightforward. The Second Amendment’s plain text protects the right to keep and bear arms. That right includes the right to acquire arms. See Heller, 554 U.S. at 583–84, 629; Ezell v. City of Chicago, 651 F.3d 684, 704 (7th Cir. 2011). Glock-pattern pistols are the most popular semi-automatic handguns in America. They are not “dangerous and unusual” weapons; they are paradigmatic arms in common use. Because the plain text covers the conduct (acquisition of common handguns), the burden shifts to the government under Bruen Step Two. The government must demonstrate that a ban on the commercial sale of an entire class of common semi-automatic handguns — justified solely by their potential for illegal conversion — is consistent with the Nation’s historical tradition of firearm regulation. No such tradition exists. Founding-era and Reconstruction-era regulations targeted the misuse of arms or the carrying of arms in a manner that terrorized the public. They did not prohibit the sale of common arms because those arms could be modified into something else. The government has never been permitted to ban a protected arm on the ground that a criminal might later commit a separate crime with an illegal accessory. This restriction also operates as an expansion of California’s long-running handgun roster regime, which is already under constitutional challenge in Renna v. Bonta.

Portable note — New Jersey device possession is not Penal Code § 27595.

California AB 1127 (Pen. Code § 27595) bans licensed-dealer sale of a “semiautomatic machinegun-convertible pistol” — the host arm — on the theory that a cruciform trigger bar can later accept an illegal auto-sear. This block’s claim is that the State may go after the conversion device; it may not ban the common handgun on that basis.

New Jersey took the device path. P.L.2025, c.363 (A4974 1R, approved January 20, 2026) is live charging law, not a pending 2026 bill. The 2026 A-3595 refile was withdrawn because this chapter already existed. Under the chapter, knowing possession of a machine-gun conversion device when the person is not in possession of a firearm to which the device may be affixed is a third-degree crime (N.J.S. 2C:39-3(l)). That is not “unaffixed to a pistol in the same room.” It is a no-host-firearm element. If the State also has a host firearm, the honest count may be machine-gun or assault-firearm possession under N.J.S. 2C:39-5, not this 2C:39-3(l) add-on. Consecutive stacking to 2C:39-5 is a separate statutory question; demand the text.

Do not mint a New Jersey twin of this California sale-ban block. On a 2C:39-3(l) calendar, demand (1) that the object meets the chapter’s conversion-device definition, (2) that the person was not in possession of a firearm to which it may be affixed, and (3) that any consecutive sentence is authorized. Confirm compiled 2C:39-1 lettering: P.L.2025, c.255 (digital instructions, January 12, 2026) and P.L.2025, c.363 (conversion device, January 20, 2026) both added a subsection (oo).