A federal appeals court on Friday dismissed a lawsuit brought by the state of California and the gun control advocacy group Giffords, which argued that a 2022 federal rule regarding untraceable "ghost guns" was not sufficiently restrictive. The 9th U.S. Circuit Court of Appeals in San Francisco ruled 3-0 to reverse a lower court decision, finding that the plaintiffs failed to prove the regulation caused them legal harm.
The litigation centered on a rule adopted during the Biden administration by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The policy requires serial numbers and background checks for ghost gun components, but California and Giffords objected to a provision that only classifies partially completed receivers—frames for AR-15 type rifles—as firearms if they are sold alongside the tools or jigs required to make them functional. The plaintiffs argued this created a loophole allowing people to buy the components separately to avoid regulation.
Writing for the panel, Circuit Judge Eric Tung stated that California did not demonstrate the rule forced the state to increase spending on law enforcement training or legislation. The court also found that Giffords did not show the ATF's interpretation undermined its mission or increased its costs. Judge Tung noted that much of the alleged harm predated the 2022 rule and characterized the plaintiffs' concerns about future exploitation of the policy as "speculation."
The scale of the impact involves the entire state of California and the federal regulatory framework managed by the ATF. While specific dollar amounts for law enforcement training were not detailed in the court's summary, the ruling prevents a court-ordered expansion of federal firearms background check requirements for component buyers. This maintains the status quo where buyers can obtain partially completed frames without federal serial numbers or background checks, provided the components are purchased without the accompanying assembly tools.
The legal landscape for this 2022 rule remains in flux due to conflicting court decisions. Just four days prior to this ruling, a U.S. District Judge in Texas found the entire ghost gun rule unconstitutional under the Second Amendment. Additionally, the U.S. Supreme Court previously addressed the rule in March 2025, reversing a separate challenge. While the Trump administration defended the rule in this specific case, the varying court opinions across different districts create a complex environment for firearm manufacturers, retailers, and owners regarding which components require serial numbers. The next steps involve potential further appeals by California and Giffords, as well as the resolution of the Texas case regarding the rule's overall constitutionality.