Wednesday, January 7, 2015

Letter to BATFE Director

Via avordvet

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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

  1. ) A “frame or receiver” and a “weapon”, are separately and uniquely defined in the GCA of 1968.
You correctly state on page 2 the following,

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!
  1. ) The “may readily be converted” phrase only applies to “weapon” and not to “receiver”.
As can be seen by your admission, these are defined separately. Therefore, you are also admitting that “may readily be converted” applies only to “weapon” and not to “frame or receiver”. Thank you for this admission!
  1. ) The meaning of the word “manufacture” is “to make into a product suitable for use.”
On page 3 you correctly quote the Broughman Case,

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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