The Second Amendment Foundation and Defense Distributed filed a motion for summary judgment on April 27 in Defense Distributed v. Blanche, asking a federal judge in the Northern District of Texas to strike down the remaining portions of the ATF's 2022 Frame and Receiver Rule — the regulation that expanded the statutory definition of "firearm" to cover unfinished frames, receivers, and parts kits. According to USA Carry, SAF filed the motion simultaneously with a second summary judgment motion in a separate challenge to NFA registration requirements for short-barreled firearms and suppressors.

The 2022 rule, issued under the Biden administration and currently still in effect, classified certain unfinished receiver blanks and parts kits as regulated firearms under the Gun Control Act, requiring serialization and transfer through a licensed dealer with a background check. SAF and Defense Distributed argue the rule exceeds ATF's statutory authority by regulating items that do not meet the GCA's definition of a firearm. The Outdoor Wire reports that the motion also contends ATF violated the Administrative Procedure Act by failing to apply the historical-tradition methodology the Supreme Court mandated in Bruen when formulating the rule.

The motion focuses specifically on the claims left unresolved by prior court action. The Fifth Circuit had already vacated significant portions of the original rule after SAF and Defense Distributed intervened, and the Supreme Court's 2025 decision in Bondi v. VanDerStok addressed only a narrow portion of the challenge, remanding the remaining statutory and constitutional questions to the district court. The summary judgment motion asks the Northern District of Texas to resolve those open questions in favor of the plaintiffs without a full trial.

The filing lands during a complicated regulatory moment. The Trump DOJ has signaled it intends to rewrite the frames-and-receivers rule but has not committed to a timeline, leaving the original 2022 regulation in place for now. Manufacturers and retailers that deal in unfinished receiver blanks, along with lawful hobbyist builders, continue operating under that framework while the case proceeds. A summary judgment ruling in SAF's favor would moot the rewrite for the affected provisions; an adverse ruling would likely accelerate DOJ's revision effort or push the litigation to the Fifth Circuit again.

The Northern District of Texas court has not yet scheduled a hearing on the motion. A government response brief is expected within the timeframe set by the court's scheduling order.