The status quo on the right to keep and bear arms in California was generally maintained from the 1923 “may issue” permit system for concealed carry (with open carriage of firearms being allowed as there was no law against it) until the 1967 passage of strict gun control called the Mulford Act under Governor Ronald Reagan, which prevented open carry. The reason behind this system, where open carry was allowed but concealed carry was not, is not exactly linear. The state, long after dueling culture was abandoned, effectively banned concealed carry though a permit system where permits were usually not handed out as a way to control Chinese and Mexican Hispanic access to arms, not to dampen honor culture, which was the original reason for the first wave of 19th Century concealed carry laws in the South. California had even repealed a concealed carry ban that was in effect from 1863-1870. However, because there was concern that a total ban on any kind of carriage of arms would be a violation of the Second Amendment, open carry was allowed in public places, even if it was perhaps socially unacceptable at times as the Black Panthers’ actions show. What remained after the Mulford Act was a very restrictive concealed carry permit system and a very restrictive open carry system, effectively limiting the right to keep and bear arms to one’s property.