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
The Fight to Protect the Firearms Industry Continues

News  

Wednesday, September 23, 2026

The Fight to Protect the Firearms Industry Continues

The political lawfare campaign to dismantle the lawful firearms industry by holding it liable for the criminal misuse of its constitutionally protected products should have never started. U.S. tort law has long held that a ...

Taxpayer-Funded Orgs Bankroll Ad Council “Children” and Firearms Propaganda

News  

Monday, October 27, 2025

Taxpayer-Funded Orgs Bankroll Ad Council “Children” and Firearms Propaganda

The idiot box has been living up to the nickname.

Australia’s Gun Laws, Failing in Different Ways

News  

Monday, June 2, 2025

Australia’s Gun Laws, Failing in Different Ways

Everything is relative, so the saying goes, which means that once in a while, it’s instructive to read about the gun laws and the state of gun rights in other countries. 

Jive Turkeys: Everytown Gears Up to Spoil Thanksgiving with Gobbledygook

News  

Monday, November 17, 2025

Jive Turkeys: Everytown Gears Up to Spoil Thanksgiving with Gobbledygook

Thanksgiving in America isn’t just about food, family and football. According to a survey published by casino.ca (with its Great Thanksgiving Family Feud Map), the holiday typically “comes with a slice of family chaos and a touch of ...

Creating Crimes Out of Thin Air: Federal Bill Seeks to Treat Air Guns as Firearms

News  

Monday, October 5, 2026

Creating Crimes Out of Thin Air: Federal Bill Seeks to Treat Air Guns as Firearms

A new bill introduced in Congress proposes to regulate “lethal air guns” as firearms under the Gun Control Act of 1968, as amended (GCA). Yet the risk of fatalities and criminal misuse from air guns ...

Questions and Answers About the Texas NFA Case

News  

Monday, August 17, 2026

Questions and Answers About the Texas NFA Case

On August 12, we reported on an important development in the ongoing litigation over the National Firearms Act (NFA) filed by multiple plaintiffs in U.S. District Court for the Northern District of Texas. These included, ...

Pervasive Surveillance and Data Storage an Emerging Concern for Gun Owner Privacy

News  

Monday, October 5, 2026

Pervasive Surveillance and Data Storage an Emerging Concern for Gun Owner Privacy

Americans have willingly, and sometimes unwillingly, surrounded themselves with technology that watches, listens, records, and remembers. Cars know how and where we drive. Phones track just about everything in our daily routines. 

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 ...

Bad Faith: Gun Controllers Seek to Enlist Clergy in Firearm Confiscation Efforts

News  

Monday, October 5, 2026

Bad Faith: Gun Controllers Seek to Enlist Clergy in Firearm Confiscation Efforts

It’s often been said that gun control is really about people control. Understanding this, the megalomania gun control advocates exhibit in their never-ending pursuit to control others displays a zealotry often associated with religious fundamentalism.

St. Louis Housing Authority Evicts Man Who Police Say Acted in Self-Defense

News  

Monday, October 5, 2026

St. Louis Housing Authority Evicts Man Who Police Say Acted in Self-Defense

While the state of Missouri is considered a pro-Second Amendment state—including having Constitutional Carry—the City of St. Louis has a tendency to try to go its own way on the matter. The recent case of ...

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.