Federal court vacates Biden-era ATF rule on private gun sales after DOJ drops appeal

A federal judge in Texas formally struck down a Biden administration regulation targeting private firearms sales, issuing a final judgment after the Department of Justice abandoned its defense of the rule. The decision marks the end of a two-year legal fight waged by Gun Owners of America, the state of Texas, and several individual plaintiffs against the Bureau of Alcohol, Tobacco, Firearms and Explosives.

United States District Judge Matthew J. Kacsmaryk of the Northern District of Texas entered the final judgment Friday, the Daily Caller reported. The ruling vacated the ATF's "Definition of 'Engaged in the Business' as a Dealer in Firearms" rule, a regulation the Biden administration imposed on April 10, 2024, claiming it reflected changes in the Bipartisan Safer Communities Act.

Gun Owners of America announced the outcome on X.

"GOA won our lawsuit against the ATF's tyrannical Engaged in the Business rule. It has officially been completely VACATED!"

The group added that the ruling "means that gun owners who buy and sell firearms will be better protected against the kind of ATF raids that murdered Brian Malinowski of Arkansas." GOA did not elaborate on Malinowski's case in the post.

What the Biden-era ATF rule actually did

The regulation rewrote key definitions governing who qualifies as a firearms dealer under federal law. Before the rule, the statutory standard asked whether a person's "principal objective" in selling guns was "livelihood and profit." The Biden ATF swapped in new language. Under the revised framework, anyone "relied upon by the public" as a source of firearms or anyone showing intent to "predominantly earn a profit" from sales could be swept into the dealer category, and subjected to federal licensing requirements.

The rule went further. It declared that failing to make a profit would not spare a seller from ATF enforcement. In other words, the agency claimed authority to treat private gun owners as unlicensed dealers even when no profit motive existed.

Texas and Gun Owners of America filed a complaint arguing the statutes already carried clear definitions and that ATF was exceeding the authority Congress had granted it. Their complaint stated the regulatory power at issue "was statutorily granted to ATF by Congress", and that the agency had stretched it past the breaking point.

Two years of legal battle

The timeline tells its own story. The Biden ATF published the rule on April 10, 2024. Within two months, GOA, Texas, and several individuals secured a preliminary injunction on June 11, 2024, blocking the regulation from taking effect while the case proceeded.

The DOJ appealed that injunction to the United States Court of Appeals for the Fifth Circuit. But the legal landscape shifted after the 2024 election. In February 2025, President Donald Trump signed an executive order directing a review of ATF regulations promulgated under the Biden administration.

The Trump Justice Department, now under Acting Attorney General Todd Blanche, followed through. Roughly two weeks before an April 30 press conference, DOJ asked the Fifth Circuit to dismiss its own appeal of the district court ruling, effectively conceding the fight.

At the April 30 press conference, Blanche revealed that ATF would publish at least 34 rule changes. Those included repealing the "engaged in the business" rule, repealing the Biden-era "stabilizing brace" rule, and altering a third regulation the previous administration had used to target so-called "bump stocks." Blanche said the changes were intended to improve enforcement while complying with Trump's February 2025 executive order.

The Justice Department's willingness to reverse course on politically charged cases has become a recurring theme under the current administration.

What the ruling means going forward

Judge Kacsmaryk's final judgment does not merely pause the regulation. It vacates it entirely. The practical effect: private gun owners who buy and sell firearms without a federal dealer's license are no longer subject to the expanded definitions the Biden ATF tried to impose.

That matters because the rule's broad language had created real uncertainty for millions of Americans who occasionally sell firearms from personal collections, a practice that has always been legal under federal law, provided the seller is not "engaged in the business" of dealing. The Biden regulation threatened to collapse the distinction between a hobbyist selling a few guns and a commercial dealer operating a storefront.

The ruling also fits a broader pattern. The Biden administration leaned heavily on executive rulemaking to advance gun-control objectives that lacked the votes to pass Congress. Each time, the strategy invited legal challenges, and each time, federal courts found the agency had overreached.

Meanwhile, the Trump administration has shown it will use the same executive tools in reverse. The DOJ under Blanche has taken aggressive positions in federal court to unwind what it views as the prior administration's legal overreach.

The bigger picture on ATF overreach

The Biden ATF's approach followed a familiar script: take a statute Congress wrote with specific limits, reinterpret it through rulemaking to cover far more conduct, and dare gun owners to spend years and millions of dollars fighting back in court. The "engaged in the business" rule was one of at least three major Biden-era firearms regulations now being rolled back.

Gun Owners of America, which bankrolled the lawsuit alongside the state of Texas, framed the victory in stark terms on social media. The group's reference to Brian Malinowski of Arkansas, without further detail in the post, suggests the organization views the regulation as having had real-world consequences for gun owners who ran afoul of ATF's expanded enforcement posture.

The case also illustrates the limits of governing by regulation. When an administration cannot persuade Congress to pass a law, it reaches for the rulemaking pen. But rules written without clear statutory backing are fragile. They survive only as long as the executive branch is willing to defend them, and as long as courts agree the agency stayed within its lane.

Here, neither condition held. The Trump DOJ dropped the defense, and Judge Kacsmaryk, a Trump appointee, vacated the rule outright.

The broader question of how far ATF can stretch its regulatory authority is likely to surface again. With at least 34 rule changes in the pipeline, the current administration is signaling that it intends to reset the agency's posture across the board. Whether future administrations attempt to revive similar rules remains an open question.

Democrats have shown no shortage of willingness to clash with the Trump White House over institutional authority, and the firearms issue sits near the top of their policy wish list.

For now, the "engaged in the business" rule is gone. The court's final judgment stands. And the principle it reinforces is straightforward: federal agencies cannot rewrite the law Congress passed just because they wish Congress had passed a different one.

That used to be common sense. In Washington, apparently, it takes a federal lawsuit and two years of litigation to prove it.