邦迪诉范德斯托克案

Bondi v. Vanderstok is a landmark Supreme Court case decided on March 26, 2025, addressing the regulation of "ghost guns"—untraceable firearms assembled from parts kits. The case originated from a 2022 ATF rule that subjected weapon parts kits and unfinished frames or receivers to the Gun Control Act of 1968 (GCA). Plaintiffs, including Jennifer VanDerStok, challenged the rule, arguing that such kits fell outside the GCA's definition of "firearm". The district court and the Fifth Circuit agreed with the plaintiffs, vacating the rule. The Supreme Court reversed, holding that the ATF's rule is not facially inconsistent with the GCA. The Court found that some kits qualify as "weapons" because they can be readily converted into functional firearms, and that "frame or receiver" includes partially complete versions that can be easily finished.

The Supreme Court reversed the Fifth Circuit's decision in a 7-2 vote, with Justice Neil Gorsuch writing the majority opinion. Justices Sotomayor, Kavanaugh, and Jackson filed concurring opinions, while Justices Thomas and Alito dissented. The Court held that the ATF's rule is not facially inconsistent with the GCA and remanded the case for further proceedings. The Court also ordered petitioners to recover $4,276.51 in costs from the respondents.

Whether the ATF's 2022 rule regulating weapon parts kits and unfinished frames or receivers as "firearms" under the Gun Control Act of 1968 is facially inconsistent with the statute. The core legal question centered on statutory interpretation: does the GCA's definition of "firearm" encompass parts kits that can be readily assembled into functional weapons.

The decision upheld federal regulation of ghost guns, addressing the dramatic rise in untraceable firearms used in crimes—from 1,600 in 2017 to over 19,000 in 2021. The ruling has significant implications for gun control enforcement, allowing ATF to regulate parts kits and unfinished receivers. It also represents an important application of administrative law principles following the overruling of Chevron deference, demonstrating how courts may apply Skidmore respect to agency interpretations. The case highlights ongoing tensions between gun rights advocates and public safety concerns regarding ghost gun proliferation.