Supreme Court Ruling Could Lead to AR-15s Being Classified as Illegal Machine Guns

A recent Supreme Court ruling has raised serious concerns for gun owners across the nation. In a 7–2 decision, the court upheld the Biden administration’s regulation of so-called “ghost guns” – and according to attorney Steven Lieberman of Artemis Defense Institute, this decision opens the door for a future where AR-15s could be classified as illegal machine guns. Lieberman, speaking in a USCCA-hosted video, warned viewers that the ruling’s logic could allow the ATF to massively expand its regulatory authority over common firearms.

Justice Gorsuch’s Opinion and the Constitutional Divide

Lieberman explained that the majority opinion was penned by Justice Neil Gorsuch, known for his constitutionalist stance. Surprisingly, Gorsuch sided with the regulation, stating that the Gun Control Act of 1968 does grant the ATF the power to regulate partially finished frames and receivers. According to Lieberman, this case wasn’t just about ghost guns – it was about whether the government can treat unfinished parts as full firearms, which would force serialization and federal oversight. And it did exactly that.

Justice Thomas Sounds the Alarm

In his dissent, Justice Clarence Thomas warned of the dangerous precedent this ruling could set. As quoted by Lieberman, Thomas argued that the ATF could now reasonably claim that since machine guns are illegal, and since an AR-15 lower receiver is almost a machine gun, then AR-15s themselves might soon fall under machine gun regulation. This, Thomas said, would make millions of legal gun owners criminals overnight simply for possessing one of the most popular rifles in America.

The Disappearance of the 80% Line

One of the most critical aspects of this case, Lieberman noted, is how it erodes the traditional 80% rule – the longstanding boundary that separates unfinished parts from regulated firearms. With the court’s decision, there is no longer a clearly defined line. The ATF can now consider a product a firearm if it is “readily convertible” into one, even if it’s missing essential components or requires additional tools. “This turns the law into a moving target,” Lieberman warned.

Amy Howe Breaks Down the Majority’s Justification

In her SCOTUS Blog article, legal expert Amy Howe described the court’s reasoning in detail. Gorsuch argued that the Gun Control Act allows the ATF to regulate items that can be readily converted into working firearms. Kits like the Polymer80 “Buy Build Shoot” package were highlighted as examples – containing all parts needed to assemble a gun at home. Howe noted that while the court avoided drawing a bright legal line, it made clear that some unfinished frames fall within the scope of the law.

What Counts as a ‘Frame’ or ‘Receiver’ Now?

According to Howe, Gorsuch’s ruling leaned heavily on plain language and context. If a part looks like a gun part and only needs minor work to function, it might now qualify as a “frame” or “receiver” under the Gun Control Act. “Just look at it,” Gorsuch wrote in reference to Polymer80’s unfinished frame. But this is exactly the kind of vague standard that worries gun owners and legal analysts. As Lieberman stressed, courts are now granting federal agencies more room to decide for themselves what counts as a regulated firearm.

Tom Grieve’s Take: The Nebulous Zone

Attorney Tom Grieve, covering the case in a video shot from the snowy woods of Wisconsin, echoed Lieberman’s concerns. He called the decision “a gut punch,” and said the court essentially replaced a clear rule with a fuzzy gray area. “We’ve moved from a strong percentage line to a nebulous cloud,” Grieve said. He emphasized that the ruling didn’t fully endorse the ATF’s authority across the board, but it did legitimize their power to regulate specific ghost gun kits – and left the door wide open for future restrictions.

What This Means for AR-15 Owners

Back in the USCCA video, Lieberman dove into the possible consequences for AR-15s. Justice Thomas’ dissent described a scenario where the ATF could argue that because AR-15 receivers are “readily convertible” into machine guns, they should be regulated as such. Gorsuch tried to dismiss that concern, saying the government had no intention of making that move – but Lieberman called that assurance “disingenuous at best.” After all, promises made by government agencies in the past haven’t always been kept.

Hardware vs. Behavioral Gun Control

Lieberman also discussed a broader legal distinction: behavioral-based vs. hardware-based gun control. Behavioral laws focus on actions – like needing a permit to carry – while hardware-based laws restrict the types of guns or components you can own. The ghost gun rule is clearly a hardware-based restriction, and Lieberman expressed frustration that the Supreme Court didn’t use the case to clarify the Second Amendment’s protection over commonly owned gun parts. “This could’ve been our moment,” he said, “but we lost it.”

A Missed Opportunity to Define ‘Common Use’

Lieberman had hoped this case would provide a clear ruling on what firearms or parts qualify as being “in common use,” which would strengthen protections under the Bruen standard. That didn’t happen. Instead, the court gave the ATF the green light to push its interpretation further, and left future cases like Snoke v. Brown and Ocean State Tactical v. Rhode Island to do the heavy lifting. As Lieberman explained, the door remains open, but this ruling “did not help.”

A Shrinking Zone of Freedom

Both Grieve and Lieberman noted how this decision may signal a shift. While the Supreme Court has issued strong Second Amendment decisions in recent years, this ruling could mark the beginning of a retreat – a coalescing, as Lieberman put it, around the idea of limited federal control. Grieve wasn’t as pessimistic, saying this ruling could’ve been worse. Still, he agreed that the lack of clarity creates more legal uncertainty, and possibly new risks for gun owners who’ve done nothing wrong.

A Dangerous Road Ahead

This case – Bondi v. VanDerStok – might not outlaw AR-15s today, but it puts us closer to that possibility than ever before. If the logic in the ruling is followed to its extreme, then any part that can eventually become a working firearm could be regulated like a complete weapon. That’s a slippery slope. The Supreme Court may have intended to rule narrowly, but as Lieberman warned, it gave the ATF far too much leash. We may be entering an era where definitions shift with political winds – and the cost is constitutional clarity.