Document Type

Notes

Publication Date

5-13-2026

Keywords

Second Amendment; firearms regulation; history-and-tradition test; 3D-printing; 3D-printed firearms

Subject Category

Constitutional Law

Abstract

3D-printed firearms pose a serious threat to the public by allowing individuals to circumvent traditional regulatory safeguards. Although the first shot from a 3D-printed firearm was over a decade ago, these weapons continue to exploit gaps in the federal regulatory scheme. In the meantime, state governments have adopted a variety of approaches to regulating 3D-printed firearms. As 3D printing pushes firearms technology into the future, the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen directs Second Amendment doctrine to look to history, leaving questions over whether a decidedly historical methodology could effectively adapt to technological changes. This Note analyzes whether and to what extent governments can regulate 3D-printed firearms under Bruen, as well as evaluating how a test rooted in history and tradition fares in addressing such a uniquely modern issue. Although lawmakers can still address the threats posed by 3D-printed firearms under Bruen, this Note demonstrates that history is overall an inefficient and ineffective tool for judges to use in evaluating the constitutionality of modern gun laws. As emerging technologies continue to stretch the limits of Bruen's reasoning, courts must carefully balance historical fidelity with deference to legislative action in response to uniquely modern firearms issues in order to ensure that the Second Amendment does not become "law trapped in amber."

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