Garland v. Cargill

602 U.S. 406 (2024)

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Legal Analysis

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Nature Of The Case

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Facts

Under the National Firearms Act of 1934, a “machinegun” is “any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger.” The statutory definition also includes “any part designed and intended . . . for use in converting a weapon into a machinegun. With a machinegun, a shooter can fire multiple times, or even continuously, by engaging the trigger only once. This capability distinguishes a machinegun from a semiautomatic firearm. With a semiautomatic firearm, the shooter can fire only one time by engaging the trigger. The shooter must release and re-engage the trigger to fire another shot. Machineguns can ordinarily achieve higher rates of fire than semiautomatic firearms because the shooter does not need to release and reengage the trigger between shots. A shooter who bump fires a rifle uses the firearm’s recoil to help rapidly manipulate the trigger. The shooter allows the recoil from one shot to push the whole firearm backward. As the rifle slides back and away from the shooter’s stationary trigger finger, the trigger is released and reset for the next shot. Simultaneously, the shooter uses his non-trigger hand to maintain forward pressure on the rifle’s front grip. The forward pressure counteracts the recoil and causes the firearm (and thus the trigger) to move forward and “bump” into the shooter’s trigger finger. This bump reengages the trigger and causes another shot to fire, and so on. Bump firing does not require any additional equipment, but it is a skill that requires a good degree of practice to master. A “bump stock” is an accessory designed to make the technique easier. A bump stock replaces a semiautomatic rifle’s stock with a plastic casing that allows every other part of the rifle to slide back and forth. This casing helps manage the back-and-forth motion required for bump firing. A bump stock also has a ledge to keep the shooter’s trigger finger stationary. A bump stock does not alter the basic mechanics of bump firing. As with any semiautomatic firearm, the trigger still must be released and reengaged to fire each additional shot. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) took the position that semiautomatic rifles equipped with bump stocks were not machineguns under the statute. ATF explained that a rifle equipped with a bump stock does not “operate automatically” because “forward pressure must be applied with the support hand to the forward handguard.” Because the shooter slides the rifle forward in the stock, “to fire each shot, each succeeding shot fires with a single trigger function. ATF reversed course in response to a mass shooting in Las Vegas. A gunman fired on a crowd attending an outdoor music festival in Las Vegas, killing 58 people and wounding over 500 more. The gunman equipped his weapons with bump stocks, which allowed him to fire hundreds of rounds in a matter of minutes. ATF proposed a rule that would amend its regulations to “clarify” that bump stocks are machineguns. A new final Rule amended regulations by adding the following language: “The term ‘automatically’ as it modifies ‘shoots, is designed to shoot, or can be readily restored to shoot,’ means functioning as the result of a self-acting or self-regulating mechanism that allows the firing of multiple rounds through a single function of the trigger; and ‘single function of the trigger’ means a single pull of the trigger and analogous motions. The term ‘machinegun’ includes a bump-stock-type device, i.e., a device that allows a semi-automatic firearm to shoot more than one shot with a single pull of the trigger by harnessing the recoil energy of the semi-automatic firearm to which it is affixed so that the trigger resets and continues firing without additional physical manipulation of the trigger by the shooter.” ATF ordered owners of bump stocks to destroy them or surrender them to ATF within 90 days. Cargill (P) surrendered two bump stocks under protest. P filed suit to challenge the final Rule, asserting a claim under the Administrative Procedure Act that ATF lacked statutory authority to promulgate the final Rule because bump stocks are not “machinegun[s]” as defined in §5845(b). The District Court entered judgment for ATF. The Court of Appeals eventually reversed after rehearing en banc. It held that §5845(b) is ambiguous as to whether a semiautomatic rifle equipped with a bump stock fits the statutory definition of a machinegun. It ruled that the rule of lenity required resolving that ambiguity in P’s favor. D appealed.

Issues

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Rule Of Law

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Holding & Decision

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