The ATF Lawyer You’ve Never Heard Of: William J. Ryan’s Paper Trail on Braces, Forced Reset Triggers and Gun Trusts
Most gun owners couldn’t pick William J. Ryan out of a lineup. Nearly everything he has said about guns in public is buried in court filings. But if you owned a pistol brace in 2023, built an NFA collection through a trust, or bought a forced reset trigger, Ryan’s work touched you.
From Marine Lawyer to ATF’s Classification Chief
Ryan joined the ATF in April 2009 as a firearms and explosives attorney in Martinsburg, West Virginia, according to his own court declarations and a conference speaker bio. Before that, he was a Marine Corps judge advocate at Camp Pendleton. By early 2023, he was Acting Chief of the Firearms and Ammunition Technology Division (FATD). By that summer, he was signing filings as Chief.
Today his LinkedIn profile describes him as “Deputy Chief Counsel for a Federal Agency” who supervises 100 attorneys. The profile doesn’t name the agency. ATF is the obvious bet given his whole career, but I couldn’t confirm the agency or when he took the job, so treat that title as his own description, not an official one.
Gun Trusts and 41P
Gun owners first saw Ryan in 2015. At the NRA Firearms Law Seminar in Nashville on April 10, 2015, he spoke as an NFA Branch attorney about gun trusts.
The account comes from Pennsylvania gun-rights attorney Joshua Prince, who sues the ATF and titled his blog post “Shocking Statements/Concessions by ATF.” Keep that in mind. According to Prince, Ryan blamed much of the NFA backlog on trusts drafted by non-attorneys and fill-in-the-blank forms. Ryan said trust applications went from 45 in 2003 to 36,000 in 2012.
Prince wrote that Ryan said the ATF was “still sorting through the comments” on ATF-41P, the rule that changed how trusts and responsible persons were handled for NFA transfers. On a prohibited executor, Prince reported Ryan said the person “can’t possess it” and “it is on that person to know that.” Ryan also acknowledged that a trust counts as a “person” under the NFA but not under the Gun Control Act.
Sutherland Springs
Ryan’s most consequential testimony didn’t come in a gun-rights case. It came in Holcombe v. United States, the lawsuit over the 2017 Sutherland Springs church shooting.
On April 13, 2021, the government called Ryan to testify before Judge Xavier Rodriguez in the U.S. District Court for the Western District of Texas. Ryan told the court he had been appointed ATF’s liaison to the Department of Defense (DOD) Inspector General (IG) on the Devin Kelley case.
He also signed the ATF memo, using signature authority for the Associate Chief Counsel, that found Kelley was a prohibited person. The memo concluded Kelley was barred under 18 U.S.C. 922(g)(1) because of a felony-level court-martial conviction and under 922(g)(9) for a misdemeanor crime of domestic violence. It found he was not prohibited under (g)(4) or (g)(6).
The court later found the Air Force liable for failing to report Kelley to NICS.
Here’s the irony. Ryan was a government witness, but his testimony laid out the exact point the families needed: Kelley was prohibited and should have been in the system. The background check system didn’t fail because the law was weak. It failed because the government didn’t send in the records.
The Pistol Brace Rule
In 2023, Ryan put his name behind one of the most hated ATF rules in recent memory. On March 10, 2023, as Acting Chief of FATD, he filed a declaration in Britto v. ATF in the Northern District of Texas. He walked through the January 31, 2023 “stabilizing brace” rule, including its claim that most braced firearms are likely short-barreled rifles and its 120-day registration window.
He also addressed the pictures the ATF posted of common platforms and commercial models it considered SBRs. Ryan said those examples were informational, not final classifications, and that owners could request a classification letter for their own setup.
Four days earlier, on March 6, 2023, Ryan’s declaration was filed with the ATF’s opposition to a preliminary injunction in Firearms Regulatory Accountability Coalition (FRAC) v. Garland in North Dakota.
It didn’t end well for the ATF. On August 9, 2024, the Eighth Circuit held that the ATF’s brace test was likely arbitrary and capricious and reversed the denial of a preliminary injunction. The Fifth Circuit ruled against the agency too, and the rule was eventually abandoned.
The government posted a picture of your gun, called it a likely NFA item, and then its own classification chief told a court the picture wasn’t final. That’s the brace rule in one sentence.
Rare Breed Triggers
Ryan showed up again in the government’s case against Rare Breed Triggers over the FRT-15 in the Eastern District of New York. As Chief of FATD, he filed a declaration explaining how his division works. He said it had about 28 Firearms Enforcement Officers across five branches. He said those classifications determine whether an item falls under the GCA or NFA.
Rare Breed moved to exclude him. The company argued he was an undisclosed expert with no personal knowledge of the case. The Department of Justice called him a pure fact witness.
The court sided with DOJ. According to the government’s witness list, the motion to exclude Ryan was denied by minute entry on July 30, 2023. In May 2025, DOJ announced a settlement with Rare Breed.
The Award
Ryan also picked up an Attorney General’s Distinguished Service Award under Merrick Garland. DOJ listed him as “ATF Firearms & Ammunition Chief William J. Ryan,” alongside ATF’s regulatory affairs chief, rule writers, and the agency’s top lawyers. The release doesn’t say which rule earned the award.
What I Didn’t Find
AmmoLand News found no congressional testimony from Ryan and no Inspector General or GAO findings against him. A federal campaign finance search turned up no donations, though that search was limited and he may list a different employer or state. An X search found no posts naming him. I didn’t find any news coverage of him, including at AmmoLand.
The record does show a career ATF lawyer who sat at the center of the agency’s biggest fights over the last few years. He did it almost entirely out of sight. If he really is now one of the agency’s senior lawyers, gun owners should start paying attention to the name.
About John Crump
Mr. Crump is an NRA instructor and constitutional activist with more than 26 years of experience in networking and cybersecurity for major Fortune 100 companies. John has written about firearms, the Constitution, and cybersecurity, and has interviewed people from all walks of life. John lives in Northern Virginia with his wife and sons. Follow him on X at @right2bear, or at www.crumpy.com.