Article Info
Colorado Ghost Gun Law Gets Partial Trim
| Scope | |
|---|---|
| Jurisdiction | Colorado |
| Impact | state |
| Key Entities | |
| Appellate court issuing the partial reversal | 10th U.S. Circuit Court of Appeals |
| Plaintiff challenging Colorado's ghost gun law | National Association for Gun Rights |
| Colorado gun owner whose standing was restored by the court | Christopher Richardson |
| Trump-appointee who authored the majority opinion | Judge Joel Carson |
| Advocacy group promising challenge to new 3D-gun bill | Rocky Mountain Gun Owners |
| Legal Issues | |
| |
| What It Means | |
| |
| Timeline | |
| 2023 | Colorado passes law requiring serialization of homemade firearms and banning unlicensed 3D printing of frames and receivers |
| January 2024 | NAGR and Colorado gun owners file lawsuit challenging the law |
| May 2024 | U.S. District Judge Gallagher denies injunction and dismisses most plaintiffs for lack of standing |
| March 2025 | U.S. Supreme Court affirms ATF serialization rule but does not address private-party parts-kit concerns |
| April 24, 2025 | 10th Circuit partially reverses Gallagher, restores standing and parts-kit clarity |
Colorado Ghost Gun Law Gets Partial Trim
A federal appeals court revives part of a lawsuit against Colorado's ghost gun law — and quietly hands parts-kit builders a significant win
From The Boise Gun Club Handbook
A federal appeals court ruled Thursday that Colorado's 2023 ghost gun law does not ban building firearms from parts kits — only 3D-printed frames and receivers.
State of play: The 10th Circuit partially reversed a lower court ruling that had killed the entire lawsuit brought by the National Association for Gun Rights and several Colorado gun owners challenging the state's 2023 ghost gun law.
- Standing restored for Christopher Richardson, who owned unserialized parts made illegal under the new law
- Parts kits cleared: The court read the manufacturing ban as covering only 3D printing, not assembly from commercial parts kits
- Private sales back in play: Gun owners can now pursue claims against the law's prohibition on acquiring unserialized parts from private sellers
The key language, written by Trump-appointee Circuit Judge Joel Carson, is worth paying attention to:
"We conclude that the manufacturing ban unambiguously excludes plaintiffs' intended conduct of making PMFs from firearm parts kits."
The intrigue: The state tried to lean on an ATF rule already requiring serialization as a reason the whole lawsuit was premature. The 10th Circuit wasn't buying it. The ATF rule only covers licensed dealers — it doesn't touch private-party sales. Colorado's law does. That distinction kept the case alive.
The case goes back to U.S. District Judge Gordon Gallagher, who originally dismissed most of it. Senior Judge Paul Kelly — a Bush 41 appointee — concurred on Richardson's standing but broke with the majority on the private-sales acquisition claims. He also suggested the lower court take a hard look at whether Colorado's possession ban on unserialized frames and receivers actually holds up constitutionally under current Second Amendment doctrine. That's not binding guidance, but it's a signal worth watching.
What Colorado's doing in the meantime: State lawmakers aren't waiting for the courts. A new bill restricting 3D-printed guns designed to evade traditional receiver classifications just passed the Colorado statehouse and is sitting on the governor's desk. Rocky Mountain Gun Owners has already promised a legal challenge if it's signed.
What to watch: Whether Gallagher follows Kelly's constitutional hint when he reevaluates the injunction request — and whether the new Colorado bill gets signed and immediately lands in court.
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- J & L Gunsmithing(Chesapeake, VA)
- Oliver Firearms(Spartanburg, SC)
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