Are FRT Triggers Legal? ATF Ruling, Court Battles & State-by-State Ban Status
Forced reset triggers are legal under federal law after a May 2025 Justice Department settlement reversed the ATF’s machine gun classification. Federal courts ruled FRTs don’t meet the National Firearms Act definition because each shot requires a separate trigger pull. However, several states independently prohibit FRT possession regardless of federal law—California, Connecticut, Hawaii, Maryland, New Jersey, and others maintain bans classifying FRTs as prohibited trigger activators.
Sixteen states filed a January 2025 lawsuit challenging the federal settlement, arguing FRTs pose public safety threats. The legal landscape remains fluid with ongoing Fifth Circuit appeals and potential Supreme Court review.
What Makes FRT Triggers Different From Machine Guns?
An FRT works by using the bolt carrier’s rearward motion to push the trigger forward after each shot. This forced reset allows faster firing than traditional semi-automatic triggers, but each round still requires a separate trigger pull.
In a machine gun, holding the trigger causes continuous firing until the shooter releases it or ammunition runs out. An FRT still fires only one round per trigger pull—this distinction proved central to court rulings.
The Legal Definition That Changed Everything
The National Firearms Act defines a machine gun as a weapon that shoots “automatically more than one shot, without manual reloading, by a single function of the trigger.”
Judge Reed O’Connor determined that an FRT merely resets the trigger back into a depressed state but doesn’t actually force another trigger pull, meaning it doesn’t allow more than one round to be fired by a “single function of the trigger” under Supreme Court precedent.
The ATF’s Failed Machine Gun Classification
In March 2022, the ATF sent an Open Letter to Federal Firearms Licensees stating they had determined some unidentified forced reset triggers are “machineguns” under the Gun Control Act and National Firearms Act. The ATF launched civil and criminal enforcement actions against manufacturers, sellers, and individual FRT possessors.
ATF warned customers who owned Rare Breed FRT-15 forced reset triggers that the devices had been ruled “machineguns” by the agency and were illegal to own without NFA registration. The ATF’s seizures of the devices continued through at least September 2023.
NAGR v. Garland: The Landmark Texas Ruling
On July 23, 2024, Judge Reed O’Connor from the Federal District Court, Northern District of Texas, vacated the ATF’s ban on forced reset triggers in National Association for Gun Rights v. Garland, stating the ATF had acted beyond its statutory authority in redefining forced reset triggers as machine guns.
The winning plaintiffs included individuals Patrick Carey, Travis Speegle, and James Wheeler in the Texas/Louisiana area, plus the National Association for Gun Rights and Texas Gun Rights organizations representing 4.5 million members.
The court ordered the ATF to “return to all parties, including manufacturers, distributors, resellers, and individuals, all FRTs and FRT components confiscated or seized” specifically including Rare Breed Triggers FRT-15s and Wide Open Triggers.
How Cargill v. Garland Doomed the FRT Ban
The Supreme Court’s June 2024 Cargill decision struck down the ATF’s bump stock ban, holding that a semiautomatic rifle fires only one shot each time the shooter engages the trigger—with or without a bump stock—because the statutory text requires more than one shot “by a single function of the trigger.”
Judge O’Connor relied heavily on Cargill, noting the Supreme Court focused on the mechanical operation of the firearm rather than the shooter’s actions. He distinguished FRTs from auto sears, which “take over to retain and release the hammer for all subsequent shots so that trigger functions only once in a string of automatic fire.”
Testing showed forced reset triggers can fire at or above the rate of the military’s M-16 machine gun, which fires 700 to 970 rounds per minute. However, courts found this firing speed irrelevant to the statutory definition requiring automatic fire by a single trigger function.
The May 2025 Settlement That Changed Federal Law
In May 2025, the Justice Department agreed to a settlement with Rare Breed Triggers. The DOJ dropped its efforts to ban FRTs and acknowledged the government would no longer pursue enforcement actions related to their possession or sale.
The government agreed to return previously seized devices and allow legal sales with limitations. The settlement prohibited FRTs from being used in handguns and required Rare Breed to enforce patents against copycat designs.
What the Settlement Requires
The appeals in the Second and Fifth Circuit have been dropped, and the government dismissed its forfeiture case in the District of Utah. The United States agreed to return FRTs that were seized or taken through voluntary surrender.
Returns must be requested by individual owners by September 30, 2025, consistent with instructions provided on ATF’s website. ATF began sending notices to eligible owners no later than June 30, 2025.
The government agreed not to enforce 18 U.S.C. § 922(o) and the requirements of the National Firearms Act, Gun Control Act of 1968 as amended by the Hughes Amendment to the 1986 Firearm Owners Protection Act, or any similar statute or agency interpretation against FRT possessors.
State Laws That Trump Federal Legality
Some states independently prohibit the possession of forced reset triggers or trigger activating devices. The federal government will not enforce a ban, but individual states retain authority to regulate or prohibit these devices within their jurisdictions.
States With Confirmed FRT Bans
California: FRTs are “multiburst trigger activators” under California Penal Code section 16930. California Penal Code section 32900 prohibits possession, sale, offering for sale, manufacture, importation, giving, or lending of such devices. Violations can result in criminal charges.
Connecticut: Banned binary trigger systems with bump stock legislation, classifying possession as a class D felony.
Delaware: Prohibits rate of fire enhancement devices under legislative definition covering binary and forced reset triggers.
Hawaii: Legislature prohibits possession of “triggers that fire on pull and release” and devices that mechanically increase firing rates.
Illinois: HB5728 prohibits knowing sale, manufacture, purchase, possession, or carrying of “a rate of fire enhancement” including any device “constructed, manufactured, designed or intended to mechanically increase the rate of fire in any way.”
Maryland: Defines “rapid fire trigger activator” as anything that can be attached to firearms and increases rate of fire, including binary and forced reset trigger systems.
New Jersey: In November 2019, enacted a law banning both possession and sale of binary firearm triggers by including them in their definition of machine guns.
California Attorney General Rob Bonta issued a law enforcement bulletin in June 2025 affirming FRTs remain illegal under California law despite the federal settlement. California residents who possessed FRTs surrendered to ATF should refrain from requesting their return, and California dealers should not offer FRTs for sale.
The 16-State Lawsuit Challenging Federal Legality
In January 2025, New Jersey Attorney General Matthew Platkin led more than a dozen states in intervening to protect the FRT ban as the Trump DOJ was expected to withdraw federal defense of ATF’s machine gun classification.
Sixteen states filed a lawsuit to block the distribution of FRTs, citing public safety concerns and potential violations of federal law. The states argue that allowing these devices poses threats to public safety and would increase the risk of mass casualty events.
Machinegun conversion devices like FRTs have been frequently used in violent crimes and mass shootings. Firearms equipped with MCDs can exceed the rate of fire of many military machineguns, firing up to 20 bullets in one second. ATF noted a 1,400% rise in machinegun fire incidents from 2019 through 2021.
Fifth Circuit Appeal Still Pending
The Justice Department appealed the Texas district court ruling to the Fifth Circuit. Oral arguments took place in December 2024, with judges appearing sympathetic to plaintiffs, focusing on the trigger’s mechanical function rather than user intent.
Justice Department attorney Brad Hinshelwood argued the Texas federal court incorrectly ruled and misapplied the Supreme Court’s Cargill decision. Plaintiffs’ attorney Gary Lawkowski countered that the government is trying to “stretch the definition of machine gun beyond what the statute text will bear.”
Given the circuit split and national implications, the issue will likely reach the Supreme Court regardless of the Fifth Circuit outcome.
What Gun Owners Should Do About FRT Triggers
If You Already Own an FRT
Check your state law immediately—even though federal enforcement has stopped, state-level prosecution remains possible in ban states.
If your FRT was seized by ATF, email [email protected] with your name, mailing address, telephone number, ATF case number (if known), and ATF item number(s) (if known). Do not send duplicate requests, as this slows the process.
If you live in a jurisdiction prohibiting FRT possession, ATF will work with you to return the device where it may be lawfully possessed, or upon request, transfer the device to a third party who may lawfully receive it.
FRTs will not be returned to individuals prohibited by law from possessing firearms.
If You’re Considering Purchasing an FRT
Document your purchase and receipt for court protection if questioned by authorities. Secure legal representation if contacted by authorities about FRT possession.
Do not modify the FRT to full-auto operation—that’s federal prison. Consider storing out of state if legally allowed in your residence state.
Laws can change quickly. What’s legal today may be banned tomorrow. Buyers in banned states should expect refunds or redirected notices from dealers.
For Federal Firearms Licensees
California dealers should not offer FRTs for sale despite federal legality. All staff members who process Dealer Record of Sale transactions must be informed of state-specific prohibitions.
Dealers in other states should verify current state law before stocking or selling FRTs, as additional states may enact bans following the federal settlement.
The National Firearms Act Machine Gun Definition
The federal statutory definition of a machine gun refers to a firearm that “shoots automatically more than one shot, without manual reloading, by a single function of the trigger.”
Obtaining optimum performance and enhanced cyclic rates with an FRT depend heavily on the operating principles of the gun itself, plus the operator’s control of his trigger finger and shoulder weld. If the trigger is held fixed in its rearward position, the firearm will malfunction.
This mechanical requirement for repeated trigger movement proved fatal to ATF’s classification argument in federal court.
Twenty-Eight States Supported Striking Down the Ban
Montana Attorney General Austin Knudsen led a coalition of 28 states filing an amicus brief in the Fifth Circuit supporting the National Association for Gun Rights, asking the court to affirm the lower court’s decision and reject ATF’s overreaching attempt to classify FRTs as machine guns.
The attorneys general argued the classification stretches the definition of “machinegun” too far under the Gun Control Act because FRTs don’t fire “more than one shot by a single function of the trigger.”
States joining the brief included West Virginia, Alabama, Alaska, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, Wyoming, and the Arizona State Legislature.
Frequently Asked Questions
Are forced reset triggers legal under federal law?
Yes. After the July 2024 NAGR v. Garland ruling and May 2025 Justice Department settlement, the ATF no longer classifies FRTs as machine guns. Federal enforcement has ceased and seized devices are being returned to owners.
Can states still ban FRT triggers?
Yes. States retain authority to regulate or prohibit FRTs within their jurisdictions regardless of federal law. California, Connecticut, Delaware, Hawaii, Illinois, Maryland, New Jersey, and other states maintain independent bans.
Will the Supreme Court decide if FRTs are legal?
Likely. Given the circuit split, national implications, and ongoing Fifth Circuit appeal, the issue will probably reach the Supreme Court regardless of which side loses at the appellate level.
How do I get my seized FRT back from ATF?
Email [email protected] with your name, mailing address, phone number, ATF case number, and ATF item numbers. Requests must be submitted by September 30, 2025. ATF will coordinate return through local field offices.
What’s the difference between an FRT and a machine gun?
Machine guns fire multiple rounds with a single trigger pull by holding the trigger. FRTs automatically reset the trigger but still require a separate pull for each shot—the mechanical difference courts found dispositive.
Can I use an FRT in a handgun?
No. The May 2025 settlement specifically prohibited FRTs from being developed or designed for use in pistols as a public safety condition of the agreement.
What happens if I’m caught with an FRT in a ban state?
State prosecution remains possible. Violations range from class D felonies in Connecticut to criminal charges under California Penal Code section 32900. Consult a firearms attorney immediately if facing charges.
Disclaimer: This information is for educational purposes only and does not constitute legal advice. Consult an attorney specializing in firearms law or contact ATF directly for legal guidance on FRT trigger possession and compliance in your jurisdiction.
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About the Author
Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
Her writing blends real legal insight with plain-English explanations, helping readers stay informed and legally aware.
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