In a filing in VanDerStok et al, v. Bondi et al. (formerly VanDerStok v. Garland), the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) has asked the United States District Court for the Northern District of Texas, Fort Worth Division, to stay the case for 90 days due to an upcoming rule change.
The ATF’s Frames and Receivers Rule (officially Final Rule 2021R-05F, titled “Definition of ‘Frame or Receiver’ and Identification of Firearms”) is a 2022 regulation issued by the ATF. It updated the regulatory definitions of “firearm,” “frame,” and “receiver” under the Gun Control Act of 1968 (GCA). The rule effectively restricts the sale or transfer of most unfinished firearm frames and receivers that are not serialized – colloquially known as “80% firearms.” Although the official term is privately manufactured firearms (PMFs), anti-gun groups have demonized these items as “ghost guns.”
The rule was published in the Federal Register on April 26, 2022, and took effect on August 24, 2022. It remains in force following the U.S. Supreme Court’s 7-2 decision in Bondi v. VanDerStok (2025), which upheld the rule against a facial challenge.
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