FFL Compliance: What the Interstate Handgun Ruling Changes

On September 18, 2026, a divided three-judge panel of the U.S. Court of Appeals for the Fifth Circuit held that the federal ban on direct interstate handgun sales violates the Second Amendment. For a licensed dealer, the question is not whether to celebrate. It is what a compliance-minded owner should allow at the counter. The constitutional landscape moved; your paperwork and your state-law obligations did not.

What the Court Actually Decided

In Elite Precision Customs LLC v. ATF, No. 25-11206, the panel treated 18 U.S.C. 922(a)(3), 922(a)(5) and 922(b)(3), plus ATF's mirror regulation at 27 CFR 478.99(a), as one categorical Nonresident Handgun Purchase Ban. Applying the Bruen test, the majority held that the ban implicates the Second Amendment's plain text — the right to keep and bear arms implies the right to acquire them — and that the government failed at the historical step. The court reversed the dismissal and rendered judgment for the plaintiffs. Judge Smith wrote it, joined by Judge Engelhardt; Judge Haynes dissented. Eugene Volokh summarized the ruling at Reason.

Why Your Counter Rules Should Not Change Yet

The mandate. A Fifth Circuit judgment is not operative until the mandate issues, and rehearing or rehearing en banc can delay it. The government may seek Supreme Court review; the split with the Second Circuit on the same question makes that more likely.

The circuit map. The ruling binds courts in the Fifth Circuit — Texas, Louisiana, Mississippi. It is not a nationwide authorization.

Enforcement posture. 27 CFR 478.99(a) remains on the books, and ATF has published no guidance telling licensees what it will enforce while the case is pending.

Your exposure. Delivering a handgun to a nonresident today, on the strength of an opinion with no injunction, is not a compliance strategy. Confirm the mandate date with counsel before you touch a procedure.

Three Traps on the Other Side

The buyer's home state still governs possession. A Texas dealer cannot cure a California roster problem or a New York permit requirement. Keep the both-states-legal discipline you apply to out-of-state long guns, and write down where you verified the buyer's state rules.

The federal core is untouched. Form 4473, NICS, the acquisition and disposition record, ID verification and the ban on transferring to a prohibited person apply exactly as before, as does 18 U.S.C. 922(g).

Multiple-handgun reporting still bites. Under 27 CFR 478.126a, two or more pistols or revolvers to the same unlicensed person at one time, or within five consecutive business days, require Form 3310.4: two copies to ATF and one to the state or local agency where the sale occurred, by close of business that day, with a copy attached to the 4473.

What a Well-Run FFL Does This Week

  • Ask ATF's industry liaison or your local field office, in writing, whether the judgment is operative or stayed.
  • Write a one-page policy while the answer is boring: no nonresident handgun deliveries today; here is the checklist if relief becomes operative.
  • Brief every counter employee so the answer is consistent, documented, and not improvised at the register.
  • Diarize the docket and re-check it before the next gun show.

Inspection Exposure Did Not Move

ATF's inspection program is unchanged: investigators review your bound book, 4473s, inventory and compliance with federal, state and local law. A willful violation — transferring to a prohibited person, skipping a required background check, falsifying records, ignoring a trace request, or refusing an inspection — still produces a notice of revocation. ATF's current Administrative Action Policy deemphasizes immaterial paperwork errors and ended the earlier zero-tolerance policy, and licensees revoked under it may reapply. The agency has also proposed rescinding parts of the 2024 engaged-in-the-business rule. None of that lowers the standard for a knowing transfer to someone who cannot lawfully receive a handgun.

Bottom line: Elite Precision is a real victory and a good reason to re-read your out-of-state policy — not to rewrite counter procedures before the mandate issues and your lawyer signs off. Compliance rewards patience and dull paperwork.