The Wire · CalGunHub

Supreme Court upholds ATF frame or receiver rule in Bondi v. VanDerStok

Published March 26, 2025 · Updated October 12, 2026

In a 7-2 decision, the Supreme Court upheld ATF's 2022 frame or receiver rule against a facial challenge and reversed the Fifth Circuit.

Written by the CalGunHub desk from public reporting

Who this affects: The federal rule remains in effect nationwide, including for California sellers and buyers of covered kits and frames. California separately regulates unserialized firearms and precursor parts under Penal Code section 29180 and following sections, and those state requirements are unchanged by the decision. The ruling addressed only a facial challenge, so narrower as-applied challenges remain possible. This is general information, not legal advice.

On March 26, 2025, the U.S. Supreme Court decided Bondi v. VanDerStok, No. 23-852, ruling 7-2 in an opinion by Justice Gorsuch that reversed the Fifth Circuit, according to the opinion text. The Court upheld, against a facial challenge, ATF's 2022 rule "Definition of 'Frame or Receiver' and Identification of Firearms" (87 FR 24652). The Court confirmed that the Gun Control Act's definition of firearm reaches some weapon parts kits and partially complete frames and receivers, and that the rule's serialization and background-check requirements are not facially inconsistent with the statute. The rule, in effect since August 24, 2022, applies to manufacturers, dealers, and sellers of covered kits and frames. The judgment issued April 28, 2025, and the decision expressly left room for as-applied challenges. The rule remains in effect. As the latest development, on May 6, 2026, in the EO 14206 package, ATF proposed trimming peripheral aspects of the rule, such as dealer records-retention periods (91 FR 24413), without proposing to rescind its core.

Informational only, not legal advice. Facts are attributed to the sources listed above.