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Big Update on the Legal Status of Forced Reset Triggers as of June 10, 2025

By: Griffin, Cain & Herbig, Attorneys at Law, PLLC | Published 07/12/2025

Big Update on the Legal Status of Forced Reset Triggers as of June 10, 2025

To understand the gravity of this update, and what it means; we are going to go over some ‘tuition’ on legal structures in the United States of America. In my previous post, I went over what a forced reset trigger is, and why there is a legal controversy over it.

Understanding the Relationship Between Federal, Administrative, and State Law

In the United States, our legal framework is composed of multiple layers. The layers at play for this matter are Federal Statutory Law, Administrative Law at a Federal Level, and State Law at the general level.

Federal Law is established by the U.S. Congress, interpreted by the Courts, and enforced and enacted on by the Executive branch. Federal Law applies nationwide, governing issues such as interstate commerce and national defense. Administrative Law involves rules and regulations created by federal agencies, such as the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), to implement and enforce federal statutes. This is generally done under the Executive Branch, and the Executive will create certain administrative rules regarding a law, and the Executive’s interpretation of the law, and how they intend to enforce the law. State Law is enacted by individual states and can vary significantly, addressing matters not covered by federal law or providing additional regulations that do not infringe upon Federal laws or Constitutional rights.

Settlement Agreement and Its Impact

A significant development occurred in late May with a settlement agreement between the Department of Justice (DOJ) and Rare Breed Triggers, which reversed the previous ATF position that forced reset triggers are machine guns under administrative law concepts, which the Courts were not necessarily sold on. The Truth About Guns has a good article about the settlement agreement. This agreement marks a pivotal change, as the federal government will no longer seek to ban forced reset triggers through administrative law or executive action, allowing Rare Breed Triggers to resume sales and requiring the return of seized devices to their owners. However, it is important to note that these changes are administrative and not codified into law, meaning future administrations could potentially reverse them. Furthermore, the Federal Supreme Court has not weighed in on the matter. (Foreshadowing, much?)

State Law and ATF’s Position

According to the ATF, forced reset triggers are now considered ‘legal’ if a state permits their possession. This means that while the federal government will not enforce a ban, individual states retain the authority to regulate or prohibit these devices within their jurisdictions. Therefore, legality can vary depending on state law, and individuals should consult local regulations to ensure compliance. At this exact moment, Forced Reset Triggers appear to be entirely legal in Texas.

Ongoing Litigation

Despite the settlement between the federal government’s executive branch and the involved entities, litigation has started again regarding FRTs as a coalition of sixteen states has filed a lawsuit against the federal government, challenging the legality of forced reset triggers nationwide. The states argue that allowing these devices poses a threat to public safety and violates federal law. This lawsuit underscores the ongoing debate and legal uncertainty surrounding forced reset triggers.

Potential Federal Legislative Action

While the settlement agreement has temporarily resolved the issue at the administrative level, thereby allowing forced reset triggers at the federal level, Congress retains the power to outlaw forced reset triggers through new legislation or similar actions. This possibility remains a concern for manufacturers and owners, as legislative changes could override the current administrative stance.

In conclusion, the legal status of forced reset triggers is currently in flux, with significant changes at the federal administrative level and ongoing litigation at the state level. Individuals and businesses should stay informed about developments in both federal and state law to navigate this complex legal landscape effectively.

If you have any concerns or questions about the legality of some of your firearms, or are thinking about getting into manufacturing firearms, quality counsel can assist you in this matter, and GCH Lawyers would be happy to help you out.

Robert S. Griffin