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The Second Amendment Foundation scored a major victory against the ATF’s 2022 “Frame or Receiver” Rule.

A federal judge in Texas ruled that the regulation violates both the Second Amendment and the Fifth Amendment’s Due Process Clause.

The court also issued a permanent injunction protecting Defense Distributed and all current and future SAF members. However, that injunction applies only to specific Defense Distributed products involved in the lawsuit.

In other words, this is a significant ruling, but it does not erase the entire ATF rule nationwide.

What Did the ATF Rule Do?

The ATF adopted the rule under the Biden administration in April 2022.

It expanded the federal definition of a firearm to include certain partially completed, disassembled or nonfunctional frames and receivers. The agency could also consider tools, jigs, templates, instructions and marketing materials when classifying an unfinished item.

That meant an incomplete piece of metal or polymer could become a regulated firearm before it functioned as one.

Once classified as a firearm, federal licensing, background-check, serialization and recordkeeping requirements could apply.

Defense Distributed and SAF challenged the rule on several grounds.

Court Says the Rule Is Too Vague

The court found that the regulation failed to clearly explain when unfinished material legally becomes a firearm frame or receiver.

ATF used terms such as “readily” completed and “clearly identifiable.” It also listed eight nonexclusive factors that agents could consider, including time, difficulty, expertise, tools, cost and parts availability.

The problem, according to the court, was that the rule never established a clear dividing line.

“The decision of when a hunk of metal or plastic” becomes a frame or receiver was left to ATF’s subjective judgment, the court wrote.

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That uncertainty created two constitutional problems. Ordinary people lacked fair notice about what the rule prohibited, and ATF agents received too much discretion when deciding what to enforce.

The judge therefore found the rule unconstitutionally vague under the Fifth Amendment.

Home Gunsmithing Is Protected Conduct

The court also sided with SAF and Defense Distributed on their Second Amendment claim.

Both parties agreed that making or repairing a personal firearm falls within the Second Amendment’s protection. That placed the burden on the government to show that the rule fit America’s historical tradition of firearm regulation.

The government cited early laws covering barrel inspections, proof marks and gunpowder storage.

The court found those laws were not close enough.

Historical barrel and gunpowder regulations focused on preventing defective products and accidental explosions. The ATF rule, by comparison, sought to control crime through firearm tracing and restrictions on unfinished components.

The court also found a long American tradition of individuals building and repairing their own firearms.

Because the government failed to provide a sufficient historical comparison, the judge ruled that applying the regulation to the plaintiffs’ products violated the Second Amendment.

Who Does the Injunction Protect?

The court declared that the challenged portions of the rule cannot be enforced against:

• Defense Distributed
• The Second Amendment Foundation
• Current SAF members
• Future SAF members

The permanent injunction is narrower than that declaration.

It blocks enforcement involving Defense Distributed’s M1911 80% Frames, G80 Build Kit, Unfinished Receiver and Grip Module.

The ruling does not create a nationwide injunction covering every gun owner, company or unfinished firearm product.

What About the Supreme Court’s Earlier Decision?

This case previously reached the U.S. Supreme Court.

In 2025, the Supreme Court ruled that the Gun Control Act allows ATF to regulate at least some weapon parts kits and partially completed frames or receivers. That decision rejected a facial challenge claiming ATF exceeded the statute itself.

However, the Supreme Court did not decide the constitutional questions raised here.

After the case returned to the district court, Defense Distributed and SAF continued their Second Amendment and due-process challenges. Those claims produced the latest ruling.

The district court rejected three additional claims alleging violations of the Administrative Procedure Act. The government therefore won summary judgment on those portions of the case.

SAF Calls It a Major Victory

SAF Executive Director Adam Kraut said the rule was both unconstitutional and impossible for ordinary citizens to understand.

“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,” Kraut said.

SAF founder Alan Gottlieb said the ruling confirms that Americans may manufacture firearms at home without automatically facing prosecution under the challenged provisions.

The court issued its opinion on Aug. 17, 2026. Further appeals remain possible.

Key Takeaways

• The judge ruled against the ATF on Second Amendment and due-process grounds.
• The court found the rule’s standards too vague.
• The ruling recognized personal firearm building and repair as protected conduct.
• Defense Distributed and current and future SAF members receive protection.
• The permanent injunction covers specific Defense Distributed products.
• The decision does not strike down the rule nationwide.
• The court rejected the plaintiffs’ three Administrative Procedure Act claims.

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