ATF’s “Firearm” and “Frame or Receiver” Rules Invalid
By Stephen P. Halbrook
The Volokh Conspiracy
September 9, 2026
The Supreme Court in Bondi v. VanDerStok (2025) rejected a challenge under the Administrative Procedure Act to a 2022 Final Rule by the Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF) expanding the definitions of “firearm” and “frame or receiver.” See my post here. However, the Court did not entertain the constitutional challenges brought by Defense Distributed. In a decision issued on August 17 in Defense Distributed v. Blanche, Judge Reed O’Connor of the Northern District of Texas declared the regulations unconstitutionally vague and violative of the Second Amendment.
“ATF’s ‘Firearm’ and ‘Frame or Receiver’ Rules Invalid,” The Volokh Conspiracy, September 9, 2026.
