Judicial Landscape & Injunction Map
Circuit split analysis, emergency stay history, and federal district injunction scopes.
Granted emergency stay of Judge O'Connor's vacatur in Garland v. VanDerStok. Heard oral arguments exploring whether component parts kits are akin to "an disassembled IKEA table or raw wood."
Unanimously held the ATF exceeded its statutory authority under the Gun Control Act (GCA) of 1968. Ruled that unfinished frames/receivers are not yet 'weapons' or 'frames'.
Initial landmark vacatur of 2022 Final Rule. Held that Congress intentionally omitted 'parts of frames or receivers' from the definition in 18 U.S.C. § 921(a)(3)(B).
Parallel actions asserting self-manufacturing of firearms is deeply rooted in American tradition, failing the Bruen/Rahimi historical analogue test.
Case Focus: Garland v. VanDerStok (No. 23-852)
SCOTUS DOCKETThe core dispute in Garland v. VanDerStok addresses whether the ATF's 2022 Final Rule (87 Fed. Reg. 24652) impermissibly expanded the statutory definition of "firearm" under 18 U.S.C. § 921(a)(3). The Solicitor General contends that firearm parts kits are readily convertible into operable weapons, while challengers argue that an unfinished component cannot simultaneously be deemed the item itself.
Primary Statute: 18 U.S.C. § 921(a)(3)
Administrative Test: APA § 706 & Loper Bright
Constitutional Test: Bruen Historical Analogue
Affected Entities: Kit Mfrs, FFL Retailers, Hobbyists
Statutory vs. Regulatory Text Comparator
Juxtaposing Congress's 1968 Gun Control Act against ATF's 2022 Final Rule (27 CFR § 478.11).
18 U.S.C. § 921(a)(3) (GCA of 1968) Congressional Text
The term "firearm" means:
(A) any weapon (including a starter gun) which will or is designed to or may readily be converted to expel a projectile by the action of an explosive;
(B) the frame or receiver of any such weapon;
(C) any firearm muffler or firearm silencer; or
(D) any destructive device. Such term does not include an antique firearm.
27 CFR § 478.11 / § 478.12 (2022 Rule) Agency Expansion
"Frame or receiver" is expanded to include:
A partially complete, disassembled, or nonfunctional frame or receiver, including a parts kit, that is designed to or may readily be completed, assembled, restored, or converted to function as a frame or receiver...
"Firearm" further encompasses:
A weapon parts kit that is designed to or may readily be completed, assembled, restored, or converted to expel a projectile by the action of an explosive.
Constitutional & Administrative Doctrine Matrix
Tracking the two distinct doctrinal tracks under which the 2022 ATF Rule is challenged.
Administrative Law Track
Statutory AuthoritySecond Amendment Track
Constitutional ScrutinyInteractive 'Readily Converted' Assessment Matrix
Simulate how multi-factor mechanical tests (27 CFR § 478.11) evaluate unfinished receivers vs. raw forgings.