By Solange Reyner | Wednesday, 19 August 2026 12:26 PM EDT
A federal judge in Texas ruled Monday that a 2022 regulation targeting unfinished firearm components, commonly known as “ghost guns,” is unconstitutional, delivering a win to gun rights groups that have challenged the rule for more than four years.
U.S. District Judge Reed O’Connor of the Northern District of Texas ruled 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, according to the order.
The case, brought by Defense Distributed and the Second Amendment Foundation, challenged ATF’s Final Rule, which expanded the legal definition of “firearm” to include partially complete frames and receivers, along with parts kits that can be readily converted into a functioning gun.
The rule departed from a nearly 45-year-old ATF definition and was central to federal efforts to regulate unserialized, self-assembled firearms.
O’Connor found that the rule’s use of terms like “readily” and “clearly identifiable” failed to give ordinary people fair notice of what conduct is prohibited, and left too much discretion to ATF officials to decide when an unfinished part becomes a regulated firearm component.
The judge also concluded the rule violates the Second Amendment, rejecting the government’s argument that colonial-era laws requiring gun barrels to be inspected and gunpowder to be safely stored were historical analogues justifying the modern regulation.
O’Connor wrote that those laws were aimed at product safety, while the ATF rule was designed for crime control, and said the two are not “relevantly similar” under the framework set by the Supreme Court’s 2022 ruling in New York State Rifle & Pistol Association v. Bruen.
The ruling comes after a lengthy legal battle. The Supreme Court ruled in 2025, in Bondi v. VanDerStok, that ATF had the authority under federal law to regulate some unfinished frames and receivers, reversing an earlier appeals court decision.
That case involved different plaintiffs, who later dropped their claims following the Supreme Court’s decision, leaving Defense Distributed and the Second Amendment Foundation to pursue the remaining constitutional claims.
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 several of Defense Distributed’s products, including its M1911 80% frames and G80 build kits.
The judge ruled against the plaintiffs on separate procedural claims under the Administrative Procedure Act, finding the agency had adequately explained its change in policy and had properly relied on congressionally delegated authority.
Solange Reyner ✉
Solange Reyner is a journalist with more than 15 years of experience reporting on news, sports, and politics.
