Nat. Shooting Sports Foundation, Inc. v. State of California

Summary

The California Supreme Court held that Civil Code § 3531, which states that "[t]he law never requires impossibilities," is a maxim of jurisprudence serving as an interpretive canon, not a substantive basis to invalidate a statute. The court rejected the argument that impossibility of compliance with Penal Code § 31910(b)(7)(A)—the dual placement microstamping requirement for semiautomatic pistols—could render the statute unenforceable. The court reversed the Court of Appeal, concluding that § 3531 does not authorize courts to void a legislative mandate; rather, it may only aid in construing statutes to avoid absurd results consistent with legislative intent. The case clarifies that impossibility of performance does not empower courts to override a statute's plain text or purpose, and any challenge must be brought through constitutional or administrative avenues.

Holdings

1. Civil Code section 3531 is an interpretative canon for construing statutes, not a means for invalidating them. It does not empower courts to invalidate a statute based on impossibility of compliance.

Questions Presented

1. Whether Civil Code section 3531's maxim that '[t]he law never requires impossibilities' authorizes a court to invalidate Penal Code section 31910(b)(7)(A) on the ground that compliance is impossible.

Disposition

reversed_and_remanded