The court declared two key provisions of ATF’s 2022 Frame or Receiver Rule unconstitutional and permanently barred their enforcement against Defense Distributed, SAF, and SAF members for the G80 and M1911 products named in the order.
What the court held
Void for vagueness under the Fifth Amendment
The Rule fails to define when an unfinished item becomes a regulated “frame or receiver,” leaving ordinary people to guess and inviting arbitrary enforcement. The court found that whether a piece of metal or polymer “may readily be completed, assembled, restored, or otherwise converted” was left to ATF’s subjective judgment, with no fair notice to the person holding the part.
Unconstitutional under the Second Amendment
The court held that personal gunsmithing is protected conduct and that the government failed to show a historical tradition supporting the restriction. Self-manufacture of firearms was common in early America and, in the court’s words, foundational to establishing the nation.
What the order does
The order declares 27 C.F.R. §§ 478.11 and 478.12(c) unconstitutional under the Second Amendment and void for vagueness under the Fifth Amendment. It also permanently bars the federal defendants from enforcing those provisions against Defense Distributed, SAF, or SAF’s current and future members with respect to Defense Distributed’s M1911 80% Frames and G80 Build Kit, Unfinished Receiver, and Grip Module.
What it does not do
This is not a nationwide vacatur. The relief applies to the parties, to SAF members, and to the Defense Distributed products identified in the order. It does not strike the Rule for everyone, everywhere.
The government may appeal. State and local restrictions remain in effect where they apply, and every order remains subject to our shipping policies.
What this means if you are building
Nothing about how you order changes today. The products named in the order are the ones we already sell, we already ship them under the restrictions listed on our shipping page, and those restrictions still stand. What changed is the legal ground underneath them: for Defense Distributed, SAF, and SAF members, the two provisions ATF used to reach unfinished frames and receivers can no longer be enforced against these products.
Defense Distributed v. Blanche, No. 4:22-cv-00691-O (N.D. Tex. Aug. 17, 2026), Dkt. 330. Formerly captioned VanDerStok v. Bondi.
This post is a litigation update and is not legal advice. Product availability is subject to federal, state, and local law.
