NFA Ruling in Jenson v. ATF — What It Means for Illinois

Federal courts have been chipping away at the National Firearms Act's foundation with increasing confidence, and the latest ruling from Judge James Hendrix in Jenson v. ATF is worth your attention — especially if you're an Illinois gun owner watching the PICA litigation and wondering how all of this connects.

Let me explain what the court actually decided, why the legal reasoning matters, and what it could mean for the fight we're already in here in Illinois.

What Judge Hendrix decided in Jenson v. ATF

Judge Hendrix, a federal district court judge in Texas, ruled against the ATF's enforcement of certain NFA provisions, finding that the government had not carried its burden under the Bruen test — the standard the Supreme Court set in 2022 requiring the government to demonstrate that any modern firearms restriction has a genuine historical analogue rooted in the Founding era.

The core principle the court applied is the same one that's supposed to govern every Second Amendment case today: the government doesn't get to restrict arms simply because it finds the restriction convenient or politically popular. It has to show that the restriction is consistent with the historical tradition of firearm regulation in this country. When it can't, the restriction fails.

The Bruen test doesn't stop at handguns or rifles. It applies to any arm the government tries to regulate — and courts are increasingly enforcing that consistently.

Second Amendment attorney and historian Stephen Halbrook — whose scholarship on the original meaning of the Second Amendment spans decades — has been closely following these rulings and explained to Mark Smith of Four Boxes Diner why the string of recent NFA decisions represents a structural shift in how courts are reading Bruen, not just a series of lucky wins.

The Bruen framework is the same one our PICA case rides on

Here's why this matters directly to Illinois: Bevis v. City of Naperville — my case, the one Law Weapons is the lead plaintiff in — is built on exactly the same constitutional framework. PICA bans semiautomatic rifles and standard-capacity magazines. The state has to justify that ban under Bruen. It has to point to a historical tradition of banning entire categories of commonly owned arms. It cannot do that, because no such tradition exists.

Every time a court applies Bruen rigorously and the government loses, it reinforces the analytical framework that should — and we argue must — govern the outcome of our case. The legal ground is shifting. Courts that take the historical test seriously are consistently ruling against broad regulatory bans on commonly owned firearms and their components.

I've written about the Seventh Circuit's 2-1 ruling upholding PICA, and I've written about where the Supreme Court fight stands now. You can read that full background on the blog. The short version: the Seventh Circuit got it wrong, the Supreme Court has agreed to address the core question, and rulings like Jenson continue to build the evidentiary and doctrinal case for why PICA cannot survive honest scrutiny.

Why a Texas ruling has a long arm into Illinois courtrooms

District court rulings in other circuits aren't binding on the Seventh Circuit or the Supreme Court. I want to be honest about that. But that's not the whole picture.

When multiple federal courts — in different circuits, with different judges, in different cases — all apply Bruen and all arrive at the same conclusion that the government has failed to justify its regulation, that pattern matters. It signals doctrinal consensus. It signals that the government's historical arguments aren't persuasive to impartial judges who are actually doing the analysis.

The DOJ, which filed an amicus brief on our side in the PICA litigation — and sent attorney Harmeet Dhillon to argue it at the Seventh Circuit — is watching these rulings too. The broader the pattern of courts applying Bruen consistently, the stronger the argument that the Seventh Circuit's majority opinion was the outlier, not the rule.

Illinois gun owners living under PICA have been in legal limbo for over two years. A man who has lawfully owned his AR-15 for more than two decades is now technically out of compliance with a state law that can't withstand the constitutional test the Supreme Court already established. That's not a niche legal problem — that's hundreds of thousands of people in this state.

Where the NFA fight and the PICA fight converge

These cases are legally distinct — the NFA is a federal statute, PICA is a state law — but they share a common battleground. Both ask the same fundamental question: can the government prohibit or severely restrict access to a class of arms that law-abiding Americans commonly own and use, without any historical justification rooted in the Founding era?

The answer courts keep reaching, when they apply the test faithfully, is no.

For Illinois gun owners, that means the constitutional argument isn't weakening. It's strengthening. Every Bruen-based ruling that goes against the government adds to a body of law that the Supreme Court will be reading when it takes up the question our case helped put on the national map.

If you want to follow the legal filings and stay current on the docket, the federal court's CourtListener database is a reliable public source for case documents. And if you have questions about what any of this means for the firearms you own or want to purchase, our store and gunsmithing team are here to help you stay lawful while this fight plays out.

Where things stand as of July 2026

As of this writing, the Supreme Court has accepted the question of whether bans on semiautomatic rifles are constitutional. The Seventh Circuit's PICA ruling is under challenge. The DOJ has sided with plaintiffs in our litigation. And federal courts across the country are applying Bruen in ways that consistently undercut the government's historical justifications for broad arms bans.

The Jenson v. ATF ruling is one more data point in that larger picture. It won't resolve the Illinois case by itself. But it keeps the legal pressure exactly where it needs to be.

One ruling at a time, we're getting there.

— Robert Bevis, Law Weapons & Supply