We’re all hoping that 2025 will be the year where we push back against decades of 2nd Amendment encroachment. Recent court rulings have been trending pro 2A and the latest court victory by Franklin Armory and the Firearms Regulatory Accountability Coalition (FRAC) over the ATF looks to be continuing that trend.
The U.S. District Court in North Dakota issued its opinion in the FRAC and Franklin Armory firearms classification-related lawsuit against ATF. The lawsuit was filed back in 2023 and pertained to the way that ATF classified Franklin Armory’s Reformation and Antithesis firearms. The Reformation is a short barreled firearm chambered in .300 Blackout that used straight rifling. ATF considered the Reformation to be a firearm subject to GCA but not subject to NFA, but said they needed to come up with a proper classification for it. The Antithesis is a .410/.45 Colt firearm. ATF designated it a Short Barreled Rifle subject to both the GCA and NFA, despite not not meeting the legal definition of an SBR. Despite years of trying to work with the ATF on proper classifications, ATF refused and continued to stall. Thus the 2023 lawsuit to force the ATF to act.
It’s taken 2 years, but on February 18th, 2025 Judge Daniel M. Traynor issued his ruling vacating the ATF’s prior misclassifications of Franklin Armory’s Reformation and Antithesis firearms. Franklin Armory points out that Judge Traynor’s ruling solidifies what the firearms industry has known for years: that the ATF has been abusing its firearms technology classification powers. They’ve gotten away with it for decades unchallenged but it looks like the courts are finally taking notice.
The Court’s Opinion:
Franklin Armory presented a square peg, and ATF shoved it into a round hole. If Congress wanted “shotgun” to be a catch-all category for anything that doesn’t fit “rifle,” it could have done so. . . . . It is not for ATF to redefine the terms because it thinks Congress didn’t intend a certain outcome. Therefore, ATF exceeded its authority in defining “smoothbore” as anything lacking “functional rifling.”
So, does this mean that the Reformation and Antitheis will finally be available for purchase? Hopefully, but it’s a little early still. FRAC and Franklin Armory are having their legal counsel review Judge Traynor’s ruling to determine the future of both Reformation and Antithesis under the law. The ruling is a good precedent for other ATF overreach cases though. In response to ATF’s arguments, Judge Traynor replied that “Administrative agencies need to remember they are in the executive branch and leave legislating to Congress.”
Statement from FRAC and Franklin Armory
FRAC President & CEO, Travis White, stated that “the ATF has egregiously abused the firearms technology classification process, and this is a landmark ruling in reining in such abuses.” Franklin Armory President Jay Jacobson said, “we spent years trying to reason with ATF leadership as they failed to classify firearms correctly. We hope that future agency leaders will stick to the law as passed by Congress. All we ever wanted was a good referee, not someone to throw the game.”
Judge Traynor’s summary judgment ruling in FRAC v. Garland, No. 1:23-cv-00003, can be found here.
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