If you own or are considering purchasing a suppressor in Michigan, you have probably seen the headlines about the recent federal court ruling involving the National Firearms Act.
Updated August 21, 2026
The seven-day stay on the court’s injunction has expired, and the first suppressor transfers covered by the injunction have reportedly taken place without Form 4 approval or federal NFA registration.
That naturally raises an important question for Michigan gun owners:
Can Michigan residents now purchase a suppressor without going through the traditional NFA approval process?
Not necessarily. While the recent federal court ruling has significantly changed the federal NFA landscape, Michigan has its own statute governing suppressors, and the interaction between the federal ruling and Michigan law is not yet fully settled.
The Ruling Is Not Necessarily the Final Word
Although the seven-day period for the Department of Justice to seek an emergency stay has expired and the injunction is currently in effect for those covered by the court’s order, the case is not necessarily over.
According to current guidance from the National Shooting Sports Foundation, the Department of Justice still has until October 5, 2026, to appeal the final judgment or seek a stay while an appeal proceeds.
That means the legal landscape could change again.
An appeal could challenge the court’s ruling, seek to narrow its scope, or ultimately result in a different outcome. Until the appeal period has passed, and potentially while any appeal is being litigated, there remains significant uncertainty about the long-term status of the court’s decision.
For Michigan gun owners, this is another reason not to assume that the current federal injunction permanently eliminates the traditional NFA process.
Michigan Law Still Matters
Michigan law specifically addresses mufflers and silencers under MCL 750.224.
The statute generally prohibits the manufacture, sale, offering for sale or possession of a muffler or silencer, subject to specific exceptions contained in Michigan law.
One of those exceptions applies to a person licensed by the federal government to manufacture, sell or possess the device.
That creates an important question following the federal court ruling:
If federal law no longer requires ATF registration or approval for a particular suppressor transaction, does that transaction still satisfy Michigan’s separate statutory exception?
That is an important question for Michigan dealers and gun owners.
The federal ruling did not strike down Michigan’s statute.
The Federal Injunction Does Not Automatically Change Michigan Law
The federal court ruling concerns the federal government’s enforcement of certain NFA provisions.
It does not invalidate state firearms statutes.
That means Michigan’s existing laws remain relevant even where a particular transaction may be protected under the federal injunction.
The National Shooting Sports Foundation has specifically reminded the firearms industry that state laws continue to apply and that the effect of the federal injunction depends on the wording of each state’s individual laws.
In some states, state law specifically references federal NFA registration or compliance. In others, the language is different.
That makes it important to distinguish between what federal law currently allows for a protected transaction and what Michigan law independently requires. The federal injunction does not eliminate or override an independent requirement imposed by Michigan law. If Michigan law requires compliance with federal NFA registration or otherwise restricts possession of a suppressor, the federal court’s ruling does not automatically invalidate that state requirement.
The federal injunction does not eliminate or override an independent requirement imposed by Michigan law. If Michigan law requires compliance with federal NFA registration or otherwise restricts possession of a suppressor, the federal court’s ruling does not automatically invalidate that state requirement.
Who Is Actually Protected by the Federal Injunction?
Another important point is that the federal injunction is not a blanket exemption for every firearm owner.
The injunction applies to the named plaintiffs and qualifying members and customers covered by the court’s judgment.
That means simply being a Michigan resident does not make someone a beneficiary of the injunction.
Likewise, seeing an article online, belonging to an organization or presenting a membership card does not automatically establish that a particular transaction is covered.
The exact organization, customer, dealer, firearm and transaction can matter.
What About Form 4s?
For qualifying transactions covered by the federal injunction, certain NFA Form 4 registration and transfer approval requirements have been enjoined.
However, that does not mean a suppressor transaction becomes completely paperwork-free.
The Gun Control Act was not enjoined.
A qualifying transaction still requires the applicable Form 4473 and background check, along with the other federal firearms recordkeeping and marking requirements that remain in effect.
So even under the federal injunction, “no Form 4” does not mean “no paperwork.”
Why Red Circle Tactical Is Continuing the Existing Process
At this point, there are still too many unanswered questions for us to change our established Michigan suppressor procedures based solely on the federal ruling.
Among the issues that remain important are:
- How the federal injunction interacts with Michigan’s suppressor statute.
- Whether a particular customer is actually protected.
- Whether a particular transaction qualifies.
- How affected suppressors should move through the manufacturer, distributor and dealer chain.
- What records should be maintained.
- How an unregistered suppressor should be handled if it later crosses state lines.
- What happens if the firearm is sent out for repair.
- How a dealer would document the legal basis for the transaction years later.
- Whether additional federal or state guidance changes the analysis.
These are not questions we believe should be answered at the gun counter by a customer, a social-media post or an internet article.
What Is Red Circle Tactical Doing?
For now, Red Circle Tactical is continuing to follow the established NFA process for suppressor transfers in Michigan.
We are closely monitoring the federal litigation, NSSF guidance, ATF developments and any additional information concerning Michigan law.
We recognize that the federal ruling could ultimately result in a significant change in how suppressors are transferred.
But until we can verify that a particular transaction satisfies both federal and Michigan law, we will continue using the established process.
That isn’t ignoring the court ruling.
It is making sure we understand exactly what the ruling means before putting a customer or our FFL at risk.
What Should Michigan Customers Do?
If you are considering purchasing a suppressor, don’t assume that the federal headlines mean you can immediately take one home without a Form 4 in Michigan.
If you have questions about a particular transaction, we’re happy to discuss the current process with you.
However, we cannot currently offer a no-Form-4 transfer based solely on a customer’s membership in an organization, an internet article or another dealer’s transaction.
The federal situation is still developing, and additional guidance could change the process.
NSSF has also noted that many questions remain unanswered regarding how the federal injunction interacts with state laws that regulate suppressors. For Michigan gun owners, that distinction is especially important. A transaction may be protected from certain federal NFA requirements while still raising separate questions under Michigan law.
What Happens Next?
The current situation is still developing.
The Department of Justice declined to seek an emergency stay, allowing the injunction to take effect for the parties and transactions covered by the court’s order. However, the DOJ still has until October 5, 2026, to appeal or seek a stay of the final judgment.
At the same time, NSSF has requested additional guidance from ATF so that FFLs can better understand how to comply with the court’s ruling.
At the state level, questions concerning Michigan’s own suppressor law remain important regardless of what happens with the federal litigation.
In other words, the fact that the injunction is currently in effect does not mean the legal questions surrounding suppressor transfers are permanently settled.
We will continue monitoring the federal case, ATF guidance and developments concerning Michigan law.
If the situation changes in a way that allows us to safely and lawfully streamline suppressor transfers in Michigan, we will adjust our procedures accordingly.
The Bottom Line for Michigan Gun Owners
The federal NFA ruling is a major development.
But it does not automatically eliminate Michigan’s suppressor laws, and it does not mean every Michigan resident can simply bypass the traditional NFA process.
For now, Red Circle Tactical will continue following the established NFA transfer process while we monitor the situation.
When something changes that we can actually act on, we’ll let you know.
This article is provided for general informational purposes and is not legal advice. Federal and state firearms laws are subject to change, and individual circumstances can affect the legality of a particular firearm or transaction. Customers with questions about their specific circumstances should consult qualified legal counsel.
