A Conversation About Gun-Making in America

by
posted on August 28, 2026
** When you buy products through the links on our site, we may earn a commission that supports NRA's mission to protect, preserve and defend the Second Amendment. **

Honest historical research and analysis still matter. The Bruen test, a legal standard the U.S. Supreme Court established in New York State Rifle & Pistol Association, Inc. v. Bruen (2022) for evaluating whether a firearm regulation complies with the Second Amendment, has put an exclamation mark on this point; but then, the high court’s Second Amendment decisions leading up to Bruen would not have been possible without the historic research done by the NRA and others before the Heller (2008) decision.

In a recent example, a paper titled “The American Tradition of Self-Made Arms” was cited by a court in an important ruling on frame-or-receiver litigation. This paper was written by Joe Greenlee, director of the Office of Litigation Counsel at the NRA Institute for Legislative Action.

To discuss this case and related litigation, Greenlee came on to the NRA’s The Armed Citizen Podcast.

After being asking about the “engaged in the business” rule, which the Biden administration attempted to use to suppress the age-old practice of Americans making their own firearms, Greenlee said, “The ATF, under the Biden administration, promulgated several anti-gun rules designed to deter law-abiding citizens from engaging in lawful conduct by just keeping everything so vague that you didn’t want to risk engaging any of this activity. In the engaged in the business rule, you didn’t even have to sell a gun to be considered engaged in the business. They said if maybe even if you just advertise a gun, that would be enough. Which is a stark departure from the historical practice.

“And then another example is this frame or receiver rule, which was promulgated in 2022, which expanded the definition of firearms under the Gun Control Act of 1968 to include unfinished frames or receivers, including parts kits, and gave a really vague definition,” said Greenlee.

Greenlee explained there is still ongoing litigation in these areas. But, in the recent case in which his paper was cited, Greenlee said, “The Northern District of Texas said the rule’s actually unconstitutional because it violates the Second and Fifth Amendments. Specifically, it violates the Fifth Amendment because it’s so vague.”

After clearly explaining these issues, Greenlee responded to a question about whether he sees “things moving in the right direction or is there just a lot of work ahead?”

“Well, both,” said Greenlee. “A lot of work ahead certainly, but we are moving in a tremendous direction especially after Bruen … . Things are really going well, but it’s a long, frustrating process and there’s some losses along the way, but we’re making incredible ground.”

To keep up the momentum, NRA members need to stay involved and to inform like-minded friends and more with what is going on as we approach the Nov. 3 midterm election.

Latest

Combat Vs Gaming F
Combat Vs Gaming F

Competition Shooting vs. Combat Training

It's an undeniable fact that competition and combat solve different problems. Mistaking one for the other or rejecting either one is a mistake.

The Truth About DGUs Gun-Control Groups Don’t Want You to Know

Last August, the Centers for Disease Control and Prevention’s webpage again posted defensive-gun-use data—essentially, estimates of how many times per year armed citizens in America use guns to defend themselves or others. 

Watchtower Defense Opens New Texas Headquarters

Watchtower Defense—which has acquired the assets of Watchtower Firearms—officially opened its new headquarters and state-of-the-art manufacturing facility in Tomball, Texas.

Rifleman Review: EAA Corp. Girsan Witness2311 Match X

One of the latest 2011-style handguns out from European American Armory Corp. is its Girsan Witness2311 MatchX platform, which includes a built-in, single-port compensator and is designed for competition use.

Shell Shock & CBC Global Ammunition Sign Manufacturing Agreement

Shell Shock Technologies (SST) and CBC Global Ammunition have signed an agreement that adds manufacturing capacity, advanced tooling and new SST operations in Oklahoma and Michigan.

Short & Sweet: Springfield Armory's SA-35 4" Polished Blued

Springfield Armory continues to expand its SA-35 High Power handgun line, and one of the latest versions is this new SA-35 4" Polished Blued model that provides some added luster while remaining compact.

Interests



Get the best of American Rifleman delivered to your inbox.