The Lawyer Who Defended ATF's Brace Rule Now Acts As Chief Counsel
William J. Ryan is taking over as Acting Chief Counsel at the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), replacing Robert Leider. Most gun owners have never heard of him. His name sits in court filings, not press releases. Those filings matter, because Ryan signed declarations defending some of the agency's most contested actions of the past few years, including the 2023 pistol brace rule and the enforcement posture toward forced reset triggers. Leider drew praise from the Second Amendment community for his approach. Ryan's record tells a different story, and the switch happens at the top of the agency's legal shop.
Key Details
The facts on Ryan's career are straightforward and mostly come from his own court declarations and a conference speaker biography.
- April 2009: Ryan joined ATF as a firearms and explosives attorney in Martinsburg, West Virginia.
- Before ATF: He served as a Marine Corps judge advocate at Camp Pendleton.
- Early 2023: He became Acting Chief of the Firearms and Ammunition Technology Division (FATD).
- Summer 2023: He signed filings as Chief of that division.
- March 6, 2023: His declaration went in with ATF's opposition to a preliminary injunction in Firearms Regulatory Accountability Coalition (FRAC) v. Garland in North Dakota.
- March 10, 2023: He filed a declaration in Britto v. ATF in the Northern District of Texas.
- January 31, 2023: The "stabilizing brace" rule he defended claimed most braced firearms are likely short-barreled rifles. It set a 120-day registration window.
- Photo examples: Ryan told the court that ATF's images of braced platforms were informational, not final classifications, and that owners could request a classification letter for their own configurations.
- August 9, 2024: The Eighth Circuit held the brace test was likely arbitrary and capricious and reversed the denial of a preliminary injunction.
- Sutherland Springs: Ryan argued in court that the shooter was a prohibited person and that the Air Force failed to enter his record into the NICS database.
- Rare Breed Triggers: Ryan worked on the government's lawsuit against Rare Breed and its forced reset trigger.
- Leadership: ATF Director Robert Cekada controls the appointment, and this role is described as interim.
Background
The brace rule came out of ATF's effort to decide which pistols with stabilizing braces count as short-barreled rifles under the National Firearms Act. Owners who had built pistols with braces faced a choice: register the firearm as an SBR, modify it, or surrender it. The rule's registration deadline forced the issue quickly. Litigation followed within weeks, and multiple courts pushed back. The Eighth Circuit's August 2024 decision found the agency's test likely arbitrary and capricious. The Fifth Circuit also ruled against ATF, and the government eventually abandoned the rule. The forced reset trigger fight runs on a parallel track. ATF's earlier classification of these triggers as machine guns drew a federal lawsuit from Rare Breed Triggers. Ryan was part of the government side of that case. The broader pattern is clear. Agency lawyers defended positions that courts later rejected, and the cost landed on owners who had already bought the hardware.
Why It Matters for Gun Owners
If you own a pistol with a stabilizing brace, Ryan's work is part of your legal history. Owners who registered braced pistols, or who held onto them through the litigation, lived with the fallout. Owners of NFA items built through trusts also face the policy direction that the chief counsel's office helps shape, especially after Ryan's critics pointed to his comments about NFA trusts. Anyone who bought a forced reset trigger between the agency's classification and the later settlements should keep records of purchase dates, receipts, and any correspondence from ATF. Watch three things. First, whether the acting chief counsel's office backs off the reasoning used in the brace litigation or repeats it. Second, whether Cekada names a permanent chief counsel with a record closer to Leider's. Third, whether ATF classification letters start coming back faster. Ryan's own declaration said owners could request classification letters for their configurations. Use that process. If ATF rules a platform is not an SBR, get it in writing and keep the letter with the firearm.
DownRange Analysis
Bruen changed the calculus. Under the 2022 Supreme Court decision in New York State Rifle & Pistol Association v. Bruen, the government must justify firearm regulations by pointing to historical tradition. A rule that reclassifies common accessories as NFA items without clear statutory footing is exactly what the post-Bruen framework is supposed to catch. The brace rule's trouble in court came from that gap. A chief counsel who defended the rule once has a credibility problem with judges who now demand a historical or textual basis. So does Ryan's role survive scrutiny? The record says he served as an advocate for the agency's position, which is what lawyers do. Whether he holds personal anti-gun views is harder to prove from filings alone. The skepticism here is fair, though. He took a job in a division that writes these rules, and that is a choice. Gun owners should not assume good faith from a title. Right now, the practical move is simple. Document your firearms, keep your NFA paperwork current, request classification letters before you modify anything, and watch the Federal Register for any new rule that touches braces, triggers, or trusts.
