Federal Judge Rules ATF Frame-and-Receiver Rule Unconstitutional in Defense Distributed Case

Defense Distributed and the Second Amendment Foundation (SAF) won a significant victory in court by successfully challenging the frames-and-receivers rule as applied to the named plaintiff.

This is the latest ruling in the long-running challenge to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) April 2022 Final Rule, titled “Definition of ‘Frame or Receiver’ and Identification of Firearms.” The Rule expanded the definition of “frame or receiver” to include partially complete, disassembled, or nonfunctional frames and receivers, as well as certain parts kits that “may readily be completed.” It also allowed the ATF to consider extrinsic items such as jigs, templates, and marketing materials when classifying them.

BREAKING NEWS: Vanderstock Opinion just Released. From the Opinion:

“… A. Permanent Injunctive Relief
Plaintiffs are entitled to permanent injunctive relief. A permanent injunction is proper when a plaintiff (1) prevails on the merits, (2) there is no adequate remedy at law… pic.twitter.com/QG0qFI9Wql

— SAF (@2AFDN) August 18, 2026

After the Supreme Court’s 2025 decision in Bondi v. VanDerStok, which rejected the broader statutory challenges, only Defense Distributed and the Second Amendment Foundation remained as plaintiffs. They pursued the remaining Administrative Procedure Act (APA) claims and constitutional claims in a Texas federal district court. Both sides moved for summary judgment.

Judge Reed O’Connor has now issued a final judgment finding the ATF’s rule unconstitutional. The judge determined that the rule is void for vagueness under the Fifth Amendment’s Due Process Clause. The undefined term “readily” is governed by a non-exclusive list of eight factors (time, ease, expertise, equipment, etc.). The phrase “clearly identifiable as an unfinished component part of a weapon” provides no workable standard. A major issue is that the ATF may consider any associated jigs, templates, instructions, or marketing materials in its determination. This fails to give ordinary people fair notice of what is prohibited and invites arbitrary enforcement. The court found that the language creates more unpredictability than the Due Process Clause tolerates.

The judge also found that the rule violates the Second Amendment. The Second Amendment’s plain text covers the right to make and repair a personal firearm. This satisfies the first step of the Bruen analysis. At the second step, the government must identify historical analogues from the founding era to show that a law is consistent with the Nation’s historical tradition of firearm regulation. The government relied on colonial-era barrel-proofing and gunpowder storage laws. Those laws addressed product safety, not crime control or the tracing of unfinished frames and receivers. The judge concluded that historical tradition strongly supports the unregulated self-manufacture of arms from the colonial period through the 19th century.

“The court got it right,” said Defense Distributed founder Cody Wilson. “ATF did not respect Bruen. There is no history or tradition of regulating privately made firearms in this country.”

The plaintiffs lost on their Administrative Procedure Act claims. The judge found that the ATF adequately explained its change in position by referencing technological advances, crime data, and the grandfathering of prior classifications. The Rule relied on means-end scrutiny, but Bruen was decided after the Rule was issued, so there was no failure to consider then-controlling law. The Supreme Court in VanDerStok effectively confirmed that Congress delegated authority to the ATF to define “frame or receiver” under the Gun Control Act.

Judge O’Connor ruled that 27 C.F.R. § 478.11 and § 478.12(c) are unconstitutional under the Second Amendment and void for vagueness under the Fifth Amendment. They cannot be enforced against Defense Distributed, SAF, or any of SAF’s current or future members. He also issued a permanent injunction prohibiting the defendants from enforcing those provisions against Defense Distributed, SAF, or SAF members with respect to specific Defense Distributed products (M1911 80% Frames and the G80 Build Kit, Unfinished Receiver, and Grip Module).

This decision adds another loss to a growing list of defeats for the Department of Justice’s attempts to defend gun laws. The gun-owning public is waiting to see whether the DOJ will appeal the district court’s decision.

About John Crump

Mr. Crump is an NRA instructor and a constitutional activist. John has written about firearms, interviewed people from all walks of life, and on the Constitution. John lives in Northern Virginia with his wife and sons, follow him on X at @right2bear, or at www.crumpy.com.