Federal Judge Rules Biden-Era ATF Frame and Receiver Rule Unconstitutional

On August 17, 2026, U.S. District Judge Reed O’Connor of the Northern District of Texas issued a significant decision in Defense Distributed v. Blanche (No. 4:22-cv-00691-O, the surviving intervenor claims in the case originally filed as VanDerStok v. Garland), holding that key provisions of the Bureau of Alcohol, Tobacco, Firearms and Explosives’ 2022 “Frame or Receiver” Rule violate the Second Amendment and are void for vagueness under the Fifth Amendment’s Due Process Clause. The ruling is not a nationwide vacatur. The court declared both regulations unenforceable against Defense Distributed, the Second Amendment Foundation and any of SAF’s current or future members, and separately enjoined enforcement as to Defense Distributed’s M1911 80% Frames and its G80 Build Kit, Unfinished Receiver and Grip Module. The rule itself stays in the Code of Federal Regulations and remains enforceable against everyone outside that group.

Last updated: September 6, 2026 · Originally published August 20, 2026

The judgment draws a distinction that matters. The “declaration” is party-limited but not product-limited: the court declared the two regulations unenforceable against Defense Distributed, SAF “or any of SAF’s current or future members.” The “injunction” is narrower still, barring enforcement only “with respect to Defense Distributed’s M1911 80% Frames and G80 Build Kit, Unfinished Receiver, and Grip Module.” Judge O’Connor reasoned that an injunction should be no more burdensome than necessary to redress the plaintiffs’ particular injury.

It is also worth separating this decision from the appeal that shares its name. A case captioned Defense Distributed v. Blanche, No. 26-10244, is pending at the Fifth Circuit, but it is not an appeal of this ruling. It is an interlocutory appeal taken in March 2026 from the denial of a separate injunction motion, and it was still in merits briefing as of August 7, 2026. As of August 20, 2026 the government has filed no notice of appeal from the August 17 decision.

Background of the 2022 Rule and Litigation

In April 2022, during the Biden administration, the ATF published its Final Rule titled “Definition of ‘Frame or Receiver’ and Identification of Firearms.” The rule expanded the longstanding regulatory definitions of “firearm,” “frame,” and “receiver” under the Gun Control Act of 1968 to include partially complete, disassembled, or nonfunctional frames and receivers, as well as certain parts kits that “may readily be completed, assembled, restored, or otherwise converted” into functional firearms. This change targeted so-called “ghost guns” and “80 percent” unfinished frames and receivers, requiring serial numbers, background checks, and licensing for sellers of many such items. 

The rule marked a departure from nearly 45 years of ATF precedent that generally treated unfinished frames and receivers as non-firearms until they reached a more complete stage. Critics argued it restricted the traditional American practice of personal gunsmithing and home manufacturing of firearms. Legal challenges began almost immediately. The case originated as VanDerStok v. Garland and proceeded through the courts. An earlier phase focusing on whether the ATF exceeded its statutory authority under the Administrative Procedure Act reached the Supreme Court. In March 2025, the Court in Bondi v. VanDerStok upheld the ATF’s authority to define the terms under the statute (on a 7-2 vote), but left constitutional claims unresolved. Those Second Amendment and due process challenges continued in the district court.

The Plaintiffs

The remaining plaintiffs in this stage of the litigation were Defense Distributed, a company known for developing and distributing digital firearm design files and related products such as 80 percent frames and the Ghost Gunner CNC milling system, and the Second Amendment Foundation (SAF). SAF intervened to protect the rights of its members. Defense Distributed’s specific products at issue included its M1911 80% Frames, G80 Build Kit, unfinished receiver, and grip module.

The Court’s Decision

Judge O’Connor, a George W. Bush appointee, granted summary judgment to the plaintiffs on the constitutional claims. On the Second Amendment, he found that the rule lacks historical analogues and contradicts the longstanding American tradition of personal gunsmithing. The opinion emphasized that self-manufacture of firearms was common and foundational in early America, with no historical restrictions on individuals making arms for personal use during the 17th, 18th, or 19th centuries. Regulating access to component parts in a way that inhibits home gunsmithing, the court held, does not comport with the Second Amendment as interpreted under modern precedent such as Bruen. 

On the Fifth Amendment claim, the court ruled the rule void for vagueness. Key terms such as “readily” (governed by a non-exclusive list of factors including time, ease, expertise, and equipment) and “clearly identifiable as an unfinished component part of a weapon” fail to provide fair notice of when a piece of material or kit becomes a regulated firearm. Enforcement is left to the ATF’s subjective determination, violating due process.

The court rejected the plaintiffs’ remaining Administrative Procedure Act claims, siding with the government on those statutory issues.

Scope of the Relief

For Defense Distributed, SAF members, and those dealing in the covered products, the ruling provides immediate protection and clarity for continued production, sale, and personal manufacture of the specified unfinished frames and kits. It reaffirms the historical right to engage in personal gunsmithing without the regulatory burdens the 2022 rule imposed on these items.

Broader effects on the firearms industry are more measured. The decision strengthens Second Amendment arguments against expansive regulation of unfinished components and digital design files, potentially influencing future challenges. Companies producing 80 percent frames, 3D-printed parts, or similar products may see it as a favorable signal, though non-SAF members and other manufacturers still face the rule’s requirements unless they pursue separate litigation or the government declines to enforce it more widely. Gun control advocates have criticized the outcome and expect an appeal; the Department of Justice retains the option to seek a stay or higher-court review.

In the near term, the ruling underscores ongoing tensions over the scope of ATF authority and the boundaries of the individual right to keep and bear arms, including the right to acquire the means to manufacture firearms for personal use. As appeals or additional cases develop, the practical landscape for unfinished receivers and privately made firearms will continue to evolve.

James Nicholas

NFA Firearms Manufacturer · Professional Gunsmith for over 20 years · Firearms Writer, Photographer and Firearms Expert. The XDMAN has a talent for taking complex firearms subject matter and breaking it down into an easy-to-understand format that all experience levels can relate to.

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