## Facts

- The Gun Control Act of 1968 (GCA) regulates firearms commerce through licensing, recordkeeping, background checks, and serialization requirements.
- The GCA defines “firearm” to include (1) “any weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” and (2) “the frame or receiver of any such weapon.” 18 U.S.C. § 921(a)(3).
- In 2022, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) issued a rule interpreting these definitions to cover:
  - certain “weapon parts kits” that can be readily converted into operable firearms; and
  - “partially complete, disassembled, or nonfunctional” frames or receivers that can be readily converted into functional frames or receivers.
- The rule responded to increased availability of kits enabling home assembly of untraceable “ghost guns,” and law-enforcement reporting of substantial growth in recovered ghost guns from 2017 to 2021.
- Individual gun owners and firearms-related entities brought an Administrative Procedure Act (APA) challenge, characterizing it as a facial attack and arguing the GCA cannot reach weapon-parts kits or unfinished frames/receivers.
- The district court vacated the rule in full, and the Fifth Circuit affirmed, concluding the statute categorically excludes weapon-parts kits and covers only finished frames/receivers.
- The Supreme Court granted review.

## Issues

1. Whether the ATF’s 2022 rule interpreting the GCA to cover certain weapon-parts kits and unfinished frames/receivers is facially inconsistent with 18 U.S.C. § 921(a)(3), requiring the rule to be set aside under the APA.
2. Whether the statutory phrase “may readily be converted” can encompass at least some kits sold as collections of parts that can be assembled into an operable firearm.
3. Whether “frame or receiver” can encompass at least some partially complete, disassembled, or nonfunctional frames or receivers that can be readily completed into functional ones.

## Decision

- The Supreme Court reversed the Fifth Circuit and remanded.
- The Court held the ATF rule is not facially inconsistent with the GCA.
- The Court concluded the GCA’s text is broad enough to cover at least some weapon-parts kits that can be readily converted into a functioning firearm.
- The Court also concluded the statute can cover at least some partially complete, disassembled, or nonfunctional frames or receivers that can be readily converted into functional frames or receivers.
- The Court rejected categorical readings that would exclude all weapon-parts kits and all unfinished frames/receivers from the statute.
- Two Justices dissented, arguing the rule exceeded ATF’s statutory authority.

## Legal Principles

- A facial APA challenge fails where a rule has a substantial set of valid applications within the governing statute, even if some applications might exceed statutory coverage.
- Under the GCA, “any weapon … [that] may readily be converted” can encompass certain products sold as parts kits when they can be assembled into an operable firearm with reasonable effort.
- The GCA’s inclusion of “the frame or receiver” can extend to certain partially complete, disassembled, or nonfunctional frames or receivers when they can be readily converted into functional frames or receivers.
- Statutory purpose (supporting traceability and law-enforcement investigation through serialization and regulated commerce) may support a text-based reading that accommodates modern methods of firearm manufacture and sale.

## Conclusion

The Supreme Court upheld the ATF’s 2022 rule against a facial APA challenge, ruling that the GCA’s definitions of “firearm” and “frame or receiver” reasonably cover at least some weapon-parts kits and unfinished frames or receivers that can be readily converted into functional firearms or core firearm components.


Bondi v. VanDerStok, 145 S. Ct. 857 (2025)