The Supreme Court issued an opinion March 26, 2025, in *Bondi v. Vanderstok*, a case that addresses the scope of federal firearms regulations as they apply to modern gun manufacturing methods and so-called 'ghost guns.' The decision comes as law enforcement agencies report a dramatic increase in untraceable firearms used in crimes.
The case centers on the Gun Control Act of 1968 (GCA), which requires those engaged in importing, manufacturing, or dealing in firearms to obtain federal licenses, keep sales records, conduct background checks, and mark their products with serial numbers. The Act defines 'firearm' to include any weapon which will or is designed to or may readily be converted to expel a projectile by the action of an explosive, as well as the frame or receiver of any such weapon.
Recent years have witnessed significant changes in how guns are manufactured and sold. Companies now sell weapon parts kits that individuals can assemble into functional firearms at home. These kits vary widely in completeness and in how much work is required to finish them. Sales have grown exponentially, creating what law enforcement describes as a public safety challenge.
According to court documents, law enforcement agencies reported a dramatic increase in untraceable 'ghost guns' used in crimes, from 1,600 in 2017 to more than 19,000 in 2021. This surge prompted regulatory action by the Bureau of Alcohol, Tobacco, Firearms and Explosives.
In 2022, the ATF adopted a rule interpreting the Gun Control Act to cover weapon parts kits that are 'designed to or may readily be converted to expel a projectile.' The rule also encompasses 'partially complete, disassembled, or nonfunctional' frames or receivers. This regulatory interpretation represented the agency's response to evolving manufacturing techniques that allowed companies to sell firearm components that could be assembled into working weapons without traditional federal oversight.
The case was argued before the Supreme Court on Oct. 8, 2024. The legal dispute arose after the Fifth Circuit Court of Appeals reviewed the ATF's regulatory interpretation. The specific holding and reasoning of the Supreme Court's decision were not fully detailed in the available preliminary print, which notes that formal revisions are pending before publication of the bound volume.
The litigation involves Florida Attorney General Ashley Moody Bondi and other state officials as petitioners, with Vanderstok and other respondents challenging the federal regulation. The case represents a broader debate over how decades-old firearms statutes apply to modern manufacturing methods and emerging technologies.
The Gun Control Act of 1968 was enacted during a different era of firearms manufacturing, when guns were primarily produced by traditional manufacturers using conventional methods. The rise of weapon parts kits and home assembly has created regulatory challenges as authorities attempt to apply statutory language written before these technologies existed.
The ATF's 2022 rule aimed to address what regulators described as a gap in federal oversight. By defining weapon parts kits and partially complete receivers as firearms under existing law, the agency sought to bring these products under the same licensing, record-keeping, background check, and serial number requirements that apply to traditional firearms.
The implications of the Supreme Court's decision extend beyond the specific parties in this case. Gun manufacturers, dealers, and purchasers of weapon parts kits will need to understand how the ruling affects their operations and compliance obligations. Law enforcement agencies are also watching closely, as the decision will impact their ability to trace firearms used in criminal investigations.
The case also reflects broader tensions over firearms regulation in the United States. Supporters of the ATF rule argue it helps close a loophole that allowed untraceable firearms to proliferate. Critics contend that the regulation exceeds the agency's statutory authority and improperly expands the definition of firearms beyond congressional intent.
State and local officials have taken varying approaches to regulating ghost guns and weapon parts kits. Some jurisdictions have enacted their own restrictions, while others have challenged federal efforts to expand oversight. The Supreme Court's interpretation of federal law will likely influence these state and local regulatory approaches.
The decision comes as the Supreme Court continues to shape firearms jurisprudence following its recent rulings in cases such as *District of Columbia v. Heller* and *New York State Rifle & Pistol Association v. Bruen*, which have emphasized individual Second Amendment rights while allowing for certain regulations.
As this is a preliminary print subject to formal revision, legal practitioners and affected parties should await the final published version for complete details of the court's holding and reasoning. The Reporter of Decisions has requested notification of any typographical or formal errors before the bound volume is published.