Court Rules 2nd Amendment Covers Firearms Parts, Good News for Those Who Build Guns

A federal appeals court has ruled that firearms parts without serial numbers can be protected under the Second Amendment, a decision that firearm enthusiasts in Wyoming and across the region are celebrating. The ruling, issued April 23 by the 10th Circuit Court of Appeals, came in response to a challenge of a 2023 Colorado law that banned the purchase, sale, transfer, and possession of un-serialized firearm parts, frames, and receivers.

Casper attorney Ryan Semerad explained that the lower district court had erred by concluding the Colorado law did not implicate the Second Amendment. The 10th Circuit reversed that decision, holding that blanket prohibitions on gun parts do, in fact, bear on the right to keep and bear arms. “The government can’t just say, ‘it has nothing to do with bearing arms,’” Semerad said. Under the ruling, individuals charged in connection with firearms parts may now raise Second Amendment challenges.

For Wyomingites who build or customize their own firearms, the decision is welcome news. Nic George of Sheridan, who has been building guns for decades, likened the hobby to “Barbie dolls for men. It’s all about accessorizing.” He noted that custom-building has always involved regulated parts—typically the lower receiver on an AR-15 or the action and trigger mechanism on a bolt-action rifle. That single serialized part requires a background check and a licensed dealer. From there, owners can add barrels, sights, and other accessories to their liking.

Joshua Kinderknecht, owner of Wyoming Tactical Firearms, said building AR-15-style rifles from parts is “extremely popular.” Once a gun owner has a serialized lower receiver, the possibilities are nearly endless. A single lower can be matched with multiple upper receivers chambered for different cartridges, effectively offering several rifles in one. “I’ve got one AR lower that I have three different upper receivers for,” Kinderknecht said. “It’s really handy.”

The 10th Circuit’s ruling does not strike down the Colorado law but sends the case back for further proceedings, now with the understanding that the Second Amendment is implicated. For Wyoming gun owners, that opens the door to stronger legal protection for a hobby that has moved from fringe to mainstream. As George puts it, building your own rifle is no longer a wild-west, unregulated venture—but it is now more clearly a constitutionally protected one.