Colonial Gunsmiths Are Your Best Argument Against Ghost Gun Bans
A Bearing Arms columnist argues that building your own firearm is older than the United States, and that this history should sink ghost gun bans under the Supreme Court's Bruen standard. The case rests on Joseph G.S. Greenlee, an attorney and Second Amendment historian, whose 2023 paper, The American Tradition of Self-Made Arms, documents Americans manufacturing, assembling, and repairing their own guns from colonial times forward. Greenlee concludes that laws aimed at personally made firearms are recent, not part of the nation's regulatory tradition. The column, published October 28, 2026, takes that finding and aims it at current ghost gun litigation.
Key Details
The columnist, a history enthusiast and longtime reenactor, says he has spent roughly 40 years on living history and teaches traditional crafts such as medieval martial arts and hand-tool woodworking. He admits he has never tried historic gunsmithing, but says he plans to. He points to a recent Ammoland piece arguing that domestic gunsmiths were essential to winning the Revolution. Key points from the column and the research it cites:
- Greenlee's paper: The American Tradition of Self-Made Arms, published in 2023 by Joseph G.S. Greenlee.
- Timeline Greenlee covers: colonial America, the Revolutionary War, westward expansion, and the development of modern firearms technology.
- Core finding: restrictions specifically targeting firearms made for personal use are relatively recent, not longstanding.
- Governing test: New York State Rifle & Pistol Association v. Bruen requires the government to show that a restriction matches the nation's historical tradition of firearm regulation when the Second Amendment's plain text covers the conduct.
- The columnist's claim: ghost gun laws fail because home gunsmithing existed before the nation, continued after ratification of the Second Amendment, and continues today.
- Technology argument: the columnist concedes modern tools make building guns easier, then compares that to blogging. Easier tools, he argues, do not erase a constitutional right.
Background
The Supreme Court decided Bruen in June 2022. It threw out New York's discretionary concealed carry licensing scheme and set a new method for Second Amendment cases. Under Bruen, courts first ask whether the Second Amendment's text covers the conduct. If it does, the government must justify the restriction by pointing to historical analogues. Lower courts have since spent years arguing over how close a historical match must be, and that fight now shapes nearly every gun case in the country.
Ghost gun regulation grew out of the same period. In April 2022, the Bureau of Alcohol, Tobacco, Firearms and Explosives published a final rule expanding the legal definition of a firearm frame or receiver to cover many kits and partially finished parts. The rule took effect that August. Several states, including California, New York, and New Jersey, had already restricted unserialized homemade guns or required background checks for them. In March 2025, in Bondi v. VanDerStok, the Supreme Court upheld the ATF rule against a facial challenge by a 7-2 vote. The Court decided the case on statutory grounds under the Gun Control Act. It did not rule on whether the Second Amendment protects home manufacture.
Why It Matters for Gun Owners
This argument reaches anyone who builds, finishes, or repairs their own firearm. That group includes owners who finish 80 percent lowers, assemble kits, rebuild old rifles, or fabricate parts at a workbench. Federal rules already sweep many of these projects into regulation, and state rules in places like California, New York, New Jersey, Washington, and Colorado add serialization, licensing, or sales limits on top. A builder in those states can face felony exposure for a step that looks routine to a machinist. The practical risk is simple. Someone who buys a kit, skips the paperwork, and assumes the federal rule covers everything can end up on the wrong side of a state statute.
Watch three things. First, watch for new federal challenges that test whether the historical record Greenlee assembled gets raised in front of a court. Second, watch state legislatures, because many ghost gun statutes have been written to survive scrutiny on paper, and they vary widely. Third, watch for ATF guidance that might reinterpret the frame or receiver definition after the 2025 ruling.
DownRange Analysis
The historical argument is strong, and it deserves a real test in court. Greenlee's research identifies a long tradition of personal manufacture, and Bruen tells judges to weigh that tradition heavily. A government lawyer will argue that a general practice of home gunsmithing does not match a modern regulation on serialization or unserialized parts. That fight is where the case gets decided, and the columnist's claim that the matter is settled oversimplifies it. Still, the historical record makes a strong opening argument. Colonial gunsmiths were not a fringe practice. They were the supply chain.
What should a gun owner do now? Keep records of every build, including receipts, part sources, and dates. Know your state's rules before you order a kit or finish a receiver. Do not treat a federal rule as the only rule. Support organizations that litigate these cases, because a favorable merits ruling on personal manufacture would matter far more than any column. Build a workbench, learn the craft, and understand the law that governs it.
