BELLEVUE, Wash. — Aug. 18, 2026 — A judge in the U.S. District Court for the Northern District of Texas has ruled in favor of the Second Amendment Foundation (SAF) and Defense Distributed in Defense Distributed v. Blanche (formerly VanDerStok v. Bondi), holding the ATF’s “Frame or Receiver” Rule, which expanded the definition of a “firearm,” unconstitutional on both Second Amendment and due process grounds.
In April 2022, under the Biden administration, the ATF published its Rule amending the regulatory definition of “firearm” to encompass partially manufactured firearm frames and receivers. In seeking to regulate these “non-firearm objects” the ATF’s Rule impermissibly infringed on the Second Amendment’s protection of the right to personally manufacture and gunsmith firearms, as well as establishing a convoluted and opaque set of non-exclusive “factors” that informed when an inert piece of raw material became a “firearm” under federal law. The court declared the rule unconstitutional as applied to all SAF members and issued a permanent injunction protecting Defense Distributed and current and future Second Amendment Foundation members as it relates to the specific gun kits involved in the case. SAF and its partners filed for a motion summary judgment in April of this year, which today, the Court granted.
“This rule was such a mess that it not only violated the Second Amendment but was so terribly drafted that it managed to be ruled unconstitutionally vague,” said SAF Executive Director Adam Kraut. “The Court rightly held that the Biden ATF’s rule not only sought to outright prohibit Second Amendment protected conduct but was written in such a vague and vaporous manner as to chill that protected conduct by making it impossible to even know what was legal and what wasn’t.”
As the judge stated in the opinion, “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.”
“It was obvious from the outset that the Biden ATF’s definition of a ‘firearm’ was intentionally vague and provided no clear guidance to the average law-abiding American as to what was actually legal,” said SAF founder and Executive Vice President Alan M. Gottlieb. “As it stood previously, the updated definition, in essence, made a law-abiding citizen a criminal for nothing more than owning a piece of plastic that could be converted into a firearm. That isn’t how it works. Congress set the definition and the ATF can’t unilaterally trump up a revised version to suit their political agenda. The ruling also affirms that you are indeed allowed make firearms in your own home without fear of prosecution.”
For more information visit SAF.org.
The Second Amendment Foundation (saf.org) is the nation’s oldest and largest tax-exempt education, research, publishing and legal action group dedicated to safeguarding and promoting the fundamental rights of individuals enshrined in the Second Amendment of the United States Constitution. SAF engages in aggressive legal action to ensure the principles of armed self-defense, personal liberty, and the ownership of arms are defended, secured, and restored. Through public education initiatives, SAF teaches the importance of the Second Amendment to promote a society that values and exercises the right to keep and bear arms.
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