On March 26, 2025, the Supreme Court of the United States released its judicial opinion of Bondi v. Vanderstock (2025).
Here is a quick break down:
(a) Overview:
The Supreme Court reviewed the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) rule expanding the definition of “firearm” under the Gun Control Act (GCA) to include weapon parts kits and partially completed frames or receivers. The Fifth Circuit had previously struck down the rule, finding it inconsistent with the statutory language of the GCA.
(b) Parties:
- Petitioners: Ashley Moody, Attorney General of Florida, and the United States Government (ATF).
- Respondents: Various gun manufacturers and individuals challenging the ATF’s rule.
(c) Procedural Posture:
The District Court vacated the ATF rule, and the Fifth Circuit affirmed the decision, ruling that the GCA did not cover weapon parts kits or unfinished frames or receivers. The government sought certiorari, which the Supreme Court granted.
(d) Facts:
- The GCA requires firearm manufacturers, importers, and dealers to obtain federal licenses, conduct background checks, and apply serial numbers to firearms.
- The Act defines a “firearm” as (A) any weapon designed to or readily convertible to expel a projectile by an explosive and (B) the frame or receiver of such a weapon.
- Advances in firearm manufacturing led to a rise in “ghost guns,” untraceable firearms assembled from weapon parts kits.
- In 2022, the ATF issued a rule classifying certain kits and partially completed frames/receivers as firearms under the GCA.
- Gun manufacturers challenged the rule, arguing it exceeded ATF’s statutory authority.
- The Fifth Circuit held that the GCA did not cover weapon parts kits or unfinished frames and receivers.
(e) Question Presented:
Does the ATF’s rule interpreting the GCA to cover weapon parts kits and unfinished frames or receivers exceed the agency’s statutory authority?
(f) Holding:
No. The Supreme Court reversed the Fifth Circuit, holding that the ATF’s rule is not facially inconsistent with the GCA.
(g)Reasoning:
- Weapon Parts Kits: The Court found that the term “weapon” in the GCA can apply to unfinished objects if their intended function is clear. The Court noted that some weapon parts kits, like Polymer80’s “Buy Build Shoot” kit, contain all necessary components for a firearm and can be assembled in minutes with common tools. Since similar incomplete firearms (e.g., starter guns) are treated as weapons under the GCA, the Court held that certain kits qualify as firearms under §921(a)(3)(A).
- Partially Complete Frames and Receivers: The Court ruled that artifact nouns like “frame” and “receiver” can include unfinished versions. The GCA requires serialization of incomplete weapons and silencers, supporting ATF’s authority to regulate at least some unfinished frames and receivers.
- Rejection of Facial Challenge: Because at least some weapon parts kits and unfinished receivers clearly fall under the GCA’s scope, a facial challenge to the ATF’s rule fails.
- Rejecting Plaintiffs’ Arguments: The Court dismissed concerns about potential conflicts with the National Firearms Act (NFA) and the rule of lenity, stating that the GCA’s language supports ATF’s interpretation.
(h) Editorial Note:
- The Court emphasized that not all weapon parts kits or unfinished frames are necessarily firearms, but some clearly qualify, making a facial challenge inappropriate.
- The decision reaffirms ATF’s regulatory authority over certain firearm components, potentially impacting the ghost gun market.
(i) Dissenting Opinions:
- Justice Thomas and Justice Alito (Dissents): They argued that the statutory definition of “firearm” does not extend to unassembled kits or unfinished frames. They cautioned that the Court’s ruling improperly expands ATF’s regulatory power beyond Congress’s intent.
(j) Conclusion:
The Supreme Court upheld ATF’s rule, allowing regulation of certain weapon parts kits and unfinished frames or receivers under the GCA. The decision clarifies the definition of “firearm” in response to evolving gun manufacturing practices and the rise of untraceable weapons.
Banuelos 