Explore The NRA Universe Of Websites

APPEARS IN News

SCOTUS Statutory Ruling Not the Final Word on Biden-Era “Frame or Receiver” Rule

Monday, August 24, 2026

SCOTUS Statutory Ruling Not the Final Word on Biden-Era “Frame or Receiver” Rule

For years, NRA-ILA has closely followed and reported on the legal and regulatory saga surrounding the Biden-Harris administration’s so-called “Frame or Receiver” rule. From the rule’s earliest stages, we warned that the Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF) was attempting to stretch federal law beyond what Congress actually enacted with respect to the longstanding tradition of law-abiding citizens privately making firearms for personal use. The rule expanded federal firearm regulations to cover certain unfinished frame and receiver blanks as well as some firearm-parts kits that could be “readily” converted into functional firearms.  Predictably, litigation ensued.

Last week, a narrow but important win emerged for a case that had already traveled to the U.S. Supreme Court and back. The U.S. District Court for the Northern District of Texas, in Defense Distributed v. Blanche, concluded that the portions of the challenged ATF “frame or receiver” rule, in particular portions of 27 C.F.R.§ § 478.11 and 478.12(c), are unconstitutional on two grounds, the Second Amendment and the Fifth Amendment.

In that ruling, Chief Judge Reed O’Connor included some important findings on privately made firearms, including direct citation in the opinion to NRA-ILA’s own Director of Litigation Joseph Greenlee, confirming that:

The Final Rule does not merely lack supporting analogues. It contradicts the actual historical tradition of personal gunsmithing. Self-manufacture of firearms in America was common and indeed foundational to establishing our Nation.

The decision of when a hunk of metal or plastic “may readily be completed, assembled, restored, or otherwise converted to function as a frame or receiver” is left to the subjective determination of the ATF and does not provide fair notice to the reader about when a component becomes subject to enforcement.

NRA formally opposed the “frame or receiver” rule when it was published in 2022 and subsequently filed an amicus brief before the U.S. Supreme Court in the original case, Garland v. VanDerStok.

While the U.S. Supreme Court addressed whether the ATF has statutory room to regulate frames and receivers, this latest case asked whether ATF’s exercise of that particular authority passed constitutional muster. The answer to the first question was yes, but the answer to that second question was no.

That is what makes the ruling noteworthy. The Biden rule was written in such a vague and uncertain way that it threatened Second Amendment-protected conduct by leaving ordinary Americans unable to determine with any reasonable certainty what conduct was lawful and what might be criminal. It was the court’s conclusion that the Constitution demands better than the incomprehensible standards of the ATF regulation.  

While this latest court ruling provides party-specific relief rather than nationwide invalidation, the significance of the ruling extends beyond the parties. The decision puts a federal court squarely on record that ATF’s “frame or receiver” rule violates both the Second Amendment and the Fifth Amendment due process protections, providing a constitutional roadmap for future challenges. Since the earlier U.S. Supreme Court decision addressed ATF’s statutory authority and not these critical constitutional questions, O’Connors ruling in Defense Distributed ensures that a broader constitutional fight over the rule is just beginning.  

TRENDING NOW
More Guns, Less Homicide: Good News for America, Bad News for Gun Prohibitionists

News  

Monday, May 4, 2026

More Guns, Less Homicide: Good News for America, Bad News for Gun Prohibitionists

Homicide rates in the United States, including those where firearms are used, have been declining over the last few years.  According to multiple reports on early projections, 2025 is expected to see the largest decline in ...

President Trump Signs the “One Big Beautiful Bill Act” into Law

News  

Friday, July 4, 2025

President Trump Signs the “One Big Beautiful Bill Act” into Law

Earlier today, on the 4th of July, a day on which our Founding Fathers declared their intent for a free nation, the President of the United State of America, Donald Trump, signed the “One Big ...

The NFA’s New Era: What Has Changed, What Remains the Same, Items of Note

News  

Monday, October 12, 2026

The NFA’s New Era: What Has Changed, What Remains the Same, Items of Note

As we announced separately this week, ATF has determined that it will use its executive discretion to uniformly suspend enforcement of large portions of the National Firearms Act (NFA).

“I’m sorry, Dave, I’m afraid I can’t do that” – ChatGPT is Now “Completely Anti-gun”

News  

Monday, October 19, 2026

“I’m sorry, Dave, I’m afraid I can’t do that” – ChatGPT is Now “Completely Anti-gun”

More than half a century ago, Stanley Kubrick’s film, 2001: A Space Odyssey, introduced the world to HAL-9000, a sentient “supercomputer” with advanced artificial intelligence (AI) processing. When HAL, responsible for running the spacecraft, decides ...

Scary Stories from the Crypt Keepers at Big Gun Control

News  

Monday, October 19, 2026

Scary Stories from the Crypt Keepers at Big Gun Control

‘Tis the Halloween season of fear and disguise, and, in step with the holiday, the gun control ghouls are embracing a familiar tradition of their own. When facts aren’t quite frightening enough, firearm prohibitionists often ...

Fifth Circuit Rules Federal Switchblade Knife Restrictions Violate the Second Amendment

Friday, October 23, 2026

Fifth Circuit Rules Federal Switchblade Knife Restrictions Violate the Second Amendment

The U.S. Court of Appeals for the Fifth Circuit has ruled that the federal Switchblade Act’s restrictions on the interstate commerce of switchblade knives violate the Second Amendment.

For Better and for Worse, “Direct Democracy” Seeks to Alter Gun and Hunting Policy

News  

Wednesday, October 14, 2026

For Better and for Worse, “Direct Democracy” Seeks to Alter Gun and Hunting Policy

Not every important Second Amendment or hunting policy fight begins with a bill number.

Catch and Release: Fine for Fishing, Deadly with Violent Criminals

News  

Monday, October 19, 2026

Catch and Release: Fine for Fishing, Deadly with Violent Criminals

Our regular readers understand what should be axiomatic for all:  Violent criminals cannot prey on law-abiding citizens if they are behind bars.  Unfortunately, we are hearing more and more regularly that many in our criminal ...

Polls Show Electorate’s Interest in Gun Control Waning

News  

Monday, October 19, 2026

Polls Show Electorate’s Interest in Gun Control Waning

In late July, the White House announced that through the first half of 2026, homicides were “on pace for the lowest level in at least 126 years.” In mid-August, the FBI released data showing that ...

Federal Court Strikes Down NFA Registration Requirements for Suppressors, Short-Barreled Rifles, and Short-Barreled Shotguns in NRA Case

Wednesday, August 5, 2026

Federal Court Strikes Down NFA Registration Requirements for Suppressors, Short-Barreled Rifles, and Short-Barreled Shotguns in NRA Case

In another major victory for the National Rifle Association and law-abiding gun owners, the U.S. District Court for the Northern District of Texas today held that the National Firearms Act’s registration and approval requirements for ...

MORE TRENDING +
LESS TRENDING -

More Like This From Around The NRA

NRA ILA

Established in 1975, the Institute for Legislative Action (ILA) is the "lobbying" arm of the National Rifle Association of America. ILA is responsible for preserving the right of all law-abiding individuals in the legislative, political, and legal arenas, to purchase, possess and use firearms for legitimate purposes as guaranteed by the Second Amendment to the U.S. Constitution.