Texas Federal Court Invalidates ATF’s Ghost Gun Rule as Unconstitutional

A federal judge in Texas has ruled that a 2022 regulation targeting unfinished firearm components, commonly known as “ghost guns,” is unconstitutional, delivering a significant victory for gun rights groups that challenged the rule for more than four years.

U.S. District Judge Reed O’Connor of the Northern District of Texas declared that the Bureau of Alcohol, Tobacco, Firearms and Explosives’ definition of “frame or receiver” violates the Second Amendment and is unconstitutionally vague under the Fifth Amendment’s Due Process Clause.

The case, brought by Defense Distributed and the Second Amendment Foundation, contested ATF’s Final Rule, which expanded the legal definition of “firearm” to include partially complete frames and receivers as well as parts kits that can be readily converted into functioning firearms. The rule departed from a nearly 45-year-old ATF standard and was central to federal efforts to regulate unserialized, self-assembled weapons.

O’Connor found that terms like “readily” and “clearly identifiable” in the regulation failed to provide ordinary citizens with fair notice of prohibited conduct and left excessive discretion for ATF officials to determine when an unfinished part becomes a regulated firearm component. The judge also ruled the rule violates the Second Amendment, rejecting government arguments that colonial-era laws requiring gun barrel inspections and safe storage of gunpowder provided historical justification for modern regulation.

O’Connor noted those historical laws addressed product safety issues, while the ATF rule was designed for crime control, stating the two contexts are “not relevantly similar” under the framework established by the Supreme Court’s 2022 ruling in New York State Rifle & Pistol Association v. Bruen.

The ruling follows a protracted legal battle. In 2025, the Supreme Court decided in Bondi v. VanDerStok that ATF had authority to regulate some unfinished frames and receivers, reversing an earlier appeals court decision. That case involved different plaintiffs who withdrew their claims after the Supreme Court’s ruling, allowing Defense Distributed and the Second Amendment Foundation to pursue constitutional challenges.

O’Connor issued a permanent injunction barring the ATF from enforcing the rule against Defense Distributed, the Second Amendment Foundation, and its members. The injunction specifically covers products including Defense Distributed’s M1911 80% frames and G80 build kits. The judge also dismissed procedural claims raised by the plaintiffs under the Administrative Procedure Act, finding ATF had adequately explained its policy change and properly relied on congressionally delegated authority.