Defense Distributed v. Blanche

What the court held

This is the remand of Bondi v. VanDerStok, where the Supreme Court upheld ATF's 2022 frame-or-receiver rule against a facial APA challenge but left as-applied claims open. On August 17, 2026, Chief Judge Reed O'Connor granted partial summary judgment to Defense Distributed and the Second Amendment Foundation, holding the rule unconstitutional under the Second Amendment and void for vagueness under the Fifth Amendment — writing that when a "hunk of metal or plastic" becomes a regulated frame or receiver "is left to the subjective determination of the ATF and does not provide fair notice." The remedy comes in two pieces with different reach. The declaratory judgment states that 27 C.F.R. §§ 478.11 and 478.12(c) cannot be enforced against Defense Distributed, SAF, or any of SAF's current or future members — party-limited, but not limited to particular products. The permanent injunction, the remedy with contempt teeth, is narrower: it bars enforcement against those same parties only as to Defense Distributed's M1911 80% Frames, G80 Build Kit, Unfinished Receiver, and Grip Module. And because the plaintiffs lost their APA claims, there is no vacatur — the rule stays on the books for everyone outside those remedies, and an appeal to the Fifth Circuit is likely.

Summarized from the court's opinion.

What this case is about

As-applied Second Amendment and due-process challenges to ATF's 2022 frame-or-receiver rule, on remand after Bondi v. VanDerStok rejected only the facial APA attack

GunMapUSA summary of the issue, not a quotation from the court.

Key Dates

• 2022-08-11 — Filed as VanDerStok v. Garland
• 2026-08-17 — Frame-or-receiver rule held unconstitutional under the Second Amendment and void for vagueness; permanent injunction entered

Sources

• CourtListener — retrieved 2026-08-19
• CourtListener — retrieved 2026-08-19