Patrick “Tate” Adamiak is serving 20 years in federal prison. Not for possessing functional weapons, but for possessing items that the government’s own witnesses said could not fire a projectile.

Cut-up parts that required welding to function. Grenade-launcher components stored separately with multiple lawful uses. Two tubes stamped “INERT” and “TRAINING AID DUMMY” with a hole drilled through them.

That is what the federal government turned into a National Firearms Act conviction.

The federal government did not just “stretch” the National Firearms Act in the Patrick “Tate” Adamiak case. According to a new Supreme Court amicus brief, federal prosecutors treated cut-up parts, separated components, and inert training tubes as if they were functioning NFA weapons, then used that theory to help send a decorated Navy veteran with no prior criminal history to federal prison for 20 years.

This is the administrative gun-control machine doing what it does best: taking vague or elastic federal definitions, pushing them beyond recognition, and punishing ordinary American citizens for exercising their rights.

Now, Palmetto State Armory, the National Association for Gun Rights, and the Right to Bear Association are asking the U.S. Supreme Court to step in.

The case is Patrick Tate Adamiak v. United States, No. 25-1190. The Supreme Court docket shows the petition was filed April 10, 2026, docketed April 16, and distributed for the Court’s May 14, 2026 conference. The United States waived its right to respond unless the Court asks for one.

The May 11 amicus brief filed by NAGR, Right to Bear, and PSA cuts straight to the point: the Fourth Circuit affirmed Adamiak’s conviction after disposing of his as-applied Second Amendment claim in a single sentence, calling it “squarely foreclosed” by circuit precedent. The amici argue the court did not examine the actual conduct, did not grapple with the actual items, and did not require the government to identify any historical tradition supporting this kind of prosecution.

That is exactly the kind of lower-court evasion Bruen was supposed to stop.

The Government Treated Inoperable Objects Like Working Weapons

The facts described by the amici should alarm every collector, parts-kit owner, surplus buyer, reenactor, museum, veteran, and gun owner who has ever relied on the difference between a working weapon and a nonfunctional object.

The brief says Adamiak was sentenced to 20 years for items the government’s own witnesses acknowledged could not fire a projectile. The PPSh-pattern remnants charged in Counts One and Two had been cut into pieces and required welding to function. The grenade-launcher components in Counts Three and Four were separated and stored apart, and the government allegedly conceded the receivers had been lawfully purchased through a federal firearms licensee and had multiple lawful uses. The two RPG-7-pattern launchers in Count Five were marked “INERT” and “TRAINING AID DUMMY,” lacked firing mechanisms, and had a hole drilled through the tube.

That is the government’s theory in plain English: cut-up remnants became machinegun evidence, separated components became launcher evidence, and inert tubes became destructive-device evidence.

The ATF and federal prosecutors did not merely push the outer edge of the NFA. As the amici frame it, the government treated nonfunctional items as if they satisfied the NFA’s definitions in the first place. That is a much bigger problem than “overregulation.” It is the government using its own interpretation of technical firearms definitions to manufacture criminal liability out of objects that could not fire in the condition possessed.

PSA made the same point in its public video on the filing. The company described Adamiak as a decorated Navy veteran who served overseas for more than a decade and now sits in federal prison “not for possessing functional weapons,” but for possessing items government witnesses said could not fire a projectile. PSA described the Fourth Circuit’s treatment of the case as “no examination of the actual items, no historical analysis, no demand that the government prove its case.”

The Fourth Circuit Gave The Government A Shortcut

The Supreme Court’s Second Amendment cases are not complicated on this point. Heller recognized the individual right to keep and bear arms. McDonald applied that right against the states. Bruen told lower courts how to analyze modern gun restrictions: if the Second Amendment’s plain text covers the conduct, the government bears the burden of proving the restriction is consistent with the nation’s historical tradition of firearm regulation.

The Fourth Circuit, according to the amici, skipped that work.

It relied on Bianchi v. Brown, a so-called “assault weapon” case, and United States v. Hunt, a felon-in-possession case, to reject Adamiak’s as-applied claim. But those cases did not involve cut-up PPSh parts, separated launcher components, inert RPG-style training tubes, or nonfunctional military relics.

If a court can ignore the actual object and simply say “foreclosed,” then Bruen becomes optional. The Second Amendment becomes a right that exists in Supreme Court opinions but disappears when ATF classifications and federal prosecutors enter the room.

No other constitutional right gets treated this way. A First Amendment case requires courts to examine the actual speech. A Fourth Amendment case requires courts to examine the actual search. A Second Amendment case should require courts to examine the actual arms, parts, or objects at issue, especially when the government is seeking decades in federal prison for possesion of those arms.

The Fourth Circuit did not do that.

“Dangerous And Unusual” Does Not Cover Inert Training Aids

The amici also confront one of the government’s favorite escape hatches: Heller’s reference to “dangerous and unusual” weapons.

The brief argues that the test is conjunctive. The government must show both. Not dangerous or unusual. Dangerous and unusual.

Under the facts described by the amici, the items Adamiak was charged for possessing were neither.

An item that cannot fire a projectile is not “dangerous” in the relevant constitutional sense. An item openly sold to collectors, museums, veterans, reenactors, historical societies, and ordinary Americans is not “unusual.” The amici argue that these prosecuted items cannot satisfy either prong, much less both.

PSA’s video put it more directly: items that cannot fire a projectile are not dangerous, and items sold openly to collectors and museums are not unusual.

That is the point federal gun regulators want to blur. They want the emotional reaction to the object – “RPG,” “launcher,” “machinegun” – to replace the legal question. But the legal question is not whether an inert tube looks scary in a photo. The question is whether the object actually meets the statutory definition and whether the government’s prosecution survives the Second Amendment test required by Bruen.

If the government can call a correctly marked inert training tube a destructive device, then the limiting principle is gone.

American History Is On The Side Of Collectors, Not The ATF

The historical section of the amicus brief is especially damaging to the government’s position. NAGR, Right to Bear, and PSA argue that America does not have a historical tradition of criminalizing civilian possession of military-pattern relics, surplus arms, demilled items, or inert training devices. The historical record points the other direction.

The brief traces civilian possession of military-pattern arms from the Founding generation’s private cannon and privateers, through the post-Civil War surplus market, through the federal Civilian Marksmanship Program, and into federal statutes that recognize surplus, antiques, curios, relics, and items not designed or redesigned as weapons.

The Civilian Marksmanship Program is especially important. The brief notes that for more than 120 years, the federal government has treated civilian possession of former military arms not merely as lawful, but as a positive object of national policy. The same section points to the NFA’s own destructive-device definition, which excludes devices “neither designed nor redesigned for use as a weapon” and includes a surplus-ordnance carve-out.

That undercuts the government’s position at its foundation. If functional former military arms have long been lawfully transferred to civilians through federal policy, then inert and demilled versions are on even stronger ground. The brief argues there is no historical regulation “in any era of American law” that criminalized possession of an inert relic merely because it bore the outward form of a once-functional military weapon.

That is the history Bruen requires courts to examine. The Fourth Circuit did not require the government to confront it.

This case is about more than Patrick Tate Adamiak.

It is about whether the ATF can misread the NFA’s own definitions until cut-up remnants become “machineguns,” inert tubes become “destructive devices,” and a nonfunctional object becomes the basis for a 20-year federal sentence.

It is about whether federal prosecutors can lean on technical firearms classifications, blur the line between parts and weapons, and then tell the courts the Second Amendment has nothing to say about it.

It is about whether collectors and gun owners can rely on the law as written, or whether they must live under a system where ATF interpretation, prosecutorial discretion, and judicial rubber-stamping decide their fate after the fact.

That is not the rule of law. That is the ATF’s NFA registration racket in action and a Biden-era enforcement machine taking definitions that were already constitutionally suspect, twisting them beyond recognition, and using that interpretation to obtain a 20-year conviction over objects the government’s own witnesses said could not fire a projectile.

This is what happens when an agency shaped by anti-gun politics is allowed to decide, after the fact, that parts are weapons, inert tubes are destructive devices, and a collector is a criminal. The Second Amendment cannot survive if federal prosecutors can win convictions by relabeling nonfunctional objects and then hiding behind judicial shortcuts.

The anti-gun bureaucracy has always depended on complexity. Make the statutes dense. Make the definitions technical. Make compliance expensive. Leave grey areas intentionally to allow for politically-motivated “interpretations” to lead to life-altering convictions.

The Second Amendment is not a second-class right, and inert relics are not working weapons because the ATF wants a conviction.

The Supreme Court should grant review.

SAF Urges Supreme Court To Review Adamiak Case, Warns Courts Are Dodging Bruen

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About Duncan Johnson:

Duncan Johnson is a lifelong firearms enthusiast and unwavering defender of the Second Amendment—where “shall not be infringed” means exactly what it says. A graduate of George Mason University, he enjoys competing in local USPSA and multi-gun competitions whenever he’s not covering the latest in gun rights and firearm policy. Duncan is a regular contributor to AmmoLand News and serves as part of the editorial team responsible for AmmoLand’s daily gun-rights reporting and industry coverage.

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