On August 17, a federal judge in Fort Worth threw out a major piece of the ATF’s ghost gun rule. The ruling came out of Defense Distributed v. Blanche, heard by Chief U.S. District Judge Reed O’Connor in the Northern District of Texas, Fort Worth Division. Defense Distributed is the Austin company known for selling 80% lower receivers and build kits. The Second Amendment Foundation joined the fight as a co-plaintiff.
This case has a long history. It started as VanDerStok v. Garland back in 2022, challenging the ATF’s Frame or Receiver Rule. The Supreme Court already looked at part of this fight in Bondi v. VanDerStok in March 2025. SCOTUS ruled 7-2 that the ATF had the statutory authority to regulate at least some unfinished frames and parts kits. But SCOTUS never touched the constitutional questions. Those went back down to Judge O’Connor, and that’s what he ruled on now.
What the rule did
In April 2022, the ATF rewrote the definition of “firearm” under federal law. The new rule let ATF treat a partially finished frame or receiver as a regulated firearm the moment it could “readily be completed, assembled, restored, or otherwise converted” into one.
The problem was the word “readily.” ATF built a list of eight factors it could use to decide when a chunk of metal or polymer crossed the line into “firearm” territory: time, tools, expertise, cost, available parts, and so on. Agents could even weigh in jigs, instructions, and marketing materials.
What the court ruled
Judge O’Connor struck the rule on two separate grounds.
Second Amendment. The court held that making and repairing your own firearm is conduct the Second Amendment protects. Once that’s established, the government has to show the regulation matches this country’s historical tradition of firearm regulation. The government pointed to old barrel-proofing and gunpowder storage laws. Those laws were about product safety, not about blocking people from building their own guns. As O’Connor put it, self-manufacture of firearms in America was common and foundational to the founding of the nation.
Due process. Separately, the court found the rule void for vagueness under the Fifth Amendment. A law that can send you to federal prison has to give you fair notice of what’s illegal. O’Connor said the decision of when a piece of metal or plastic becomes a frame or receiver was left to ATF’s subjective judgment, without giving ordinary people fair notice.
What this doesn’t do
The permanent injunction only protects specific parties: Defense Distributed, the Second Amendment Foundation, and SAF’s current and future members. And it only covers specific products named in the lawsuit: Defense Distributed’s M1911 80% Frames, the G80 Build Kit, Unfinished Receiver, and Grip Module.
If you’re not an SAF member, this injunction doesn’t shield you. If you are an SAF member, you’re protected as to these products only, and you’ve got a federal court ruling on your side if the government ever tries to come after you for anything else covered by the same reasoning. SAF Executive Director Adam Kraut called the rule both unconstitutional and impossible to draft clearly enough to survive due process review.
The government can still appeal to the Fifth Circuit.
Why SAF membership matters here
This is now the third major federal injunction SAF has helped land for its members in the last few weeks. Between the post office carry ban getting struck down, the NFA suppressor and short-barreled rifle registration scheme getting gutted in Jensen v. ATF, and now this frame and receiver win, membership in these gun-rights organizations is turning into real, tangible legal protection, not just a bumper sticker.
What it means for Texas gun owners
Texas has always leaned toward protecting the right to build your own firearm. But “reinforces” isn’t the same as “guarantees.” Federal law still requires you to be legally able to possess a firearm before you manufacture one. And this injunction is narrow enough that relying on a headline instead of the actual order is a good way to end up in a legal mess.
If you’re building your own, keep good records, know exactly which products and parties this injunction covers, and don’t assume a court win in one case automatically covers your specific situation. As always, consult an attorney about your specific situation.
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