Garland v. Cargill
Headline: Court strikes down ATF rule classifying bump stocks as machineguns, stopping forced surrender orders and making it harder for the federal government to ban bump stocks without new legislation.
Holding: The Court held that ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machineguns because a bump-stock-equipped semiautomatic rifle does not fire multiple shots "automatically" by a single function of the trigger.
- Invalidates ATF's 2018 rule requiring surrender or destruction of bump stocks.
- Limits ATF's power to reclassify accessories without new legislation.
- Shifts responsibility to Congress or new rulemaking to ban bump stocks.
Summary
Background
A private gun owner, Michael Cargill, surrendered two bump stocks under protest after the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) issued a 2018 rule declaring bump stocks to be "machineguns" and ordering owners to destroy or surrender them within 90 days. ATF changed course after the 2017 Las Vegas mass shooting, where a gunman using bump-stock-equipped rifles killed 58 people and wounded over 500. Cargill sued, the district court sided with ATF, and the Fifth Circuit later reversed en banc in favor of Cargill.
Reasoning
The Court read the federal machinegun definition in 26 U.S.C. §5845(b) to require that multiple shots fire "automatically . . . by a single function of the trigger." The majority held that a semiautomatic rifle with a bump stock still requires the trigger to release and reset for each shot and requires the shooter to maintain forward pressure, so it does not fire multiple shots "by a single function of the trigger" or do so "automatically." The Court rejected ATF’s attempt to broaden the statutory language and said the presumption against ineffectiveness could not override the statute’s text.
Real world impact
The decision invalidates ATF’s 2018 classification and confirms that the agency exceeded its statutory authority in issuing that rule. As a result, ATF cannot rely on this rule to criminally require owners to surrender or destroy bump stocks; changing that outcome will require new legislation or a different lawful rulemaking.
Dissents or concurrances
Justice Alito concurred. Justice Sotomayor, joined by Justices Kagan and Jackson, dissented, arguing that bump stocks enable continuous firing with a single human action and that the Court’s reading frustrates Congress’s intent to restrict machineguns.
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