The Honorable B. Todd Jones
Director Bureau of Alcohol, Tobacco, Firearms, and Explosives
99 New York Avenue, N.E.
Washington, D.C. 20226
Dear Director Jones,
I have read ATF Rul. 2015-1 which was intended to clarify your position on several issues. I would like to thank you for your indirect admission that a firearm receiver is not a “receiver”, as defined by the GCA of 1968, until it can house all of the necessary parts that it is intended to house. I know this was not your intent. However, your words are very clear.
PART 1. Statements and Admissions
- ) A “frame or receiver” and a “weapon”, are separately and uniquely defined in the GCA of 1968.
Section 921(a)(3), defines a “firearm,” in relevant part, as both a “weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive” (921(a)(3)(A)), and the “frame or receiver of any such weapon”
You correctly observe that both a “weapon” and the “frame or receiver” of a weapon are defined separately in the GCA. Thank you for this admission!
- ) The “may readily be converted” phrase only applies to “weapon” and not to “receiver”.
- ) The meaning of the word “manufacture” is “to make into a product suitable for use.”
See Broughman at 675 (“[T]he plain and ordinary meaning of the word ‘manufacture’ is ‘to make into a product suitable for use.’” (quoting Merriam-Webster Online Dictionary (2010))…
You love to quote court cases that agree with you and ignore ones that don’t agree. However, thank you for this admission!
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