Garland v. Cargill Revisions: 6/17/24
Headline: Court blocks ATF rule and finds bump-stock-equipped semiautomatic rifles are not ‘machineguns,’ limiting agency power and easing immediate surrender requirements for owners.
Holding: The Court held that ATF exceeded its statutory authority because a semiautomatic rifle with a bump stock does not fire more than one shot by a single function of the trigger and thus is not a "machinegun".
- Invalidates ATF’s 2018 rule classifying bump stocks as machineguns.
- Owners no longer compelled by this rule to surrender or destroy bump stocks.
- Limits agency power; Congress could still change the law.
Summary
Background
The case involves Michael Cargill, who surrendered two bump stocks to the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) under protest after ATF’s 2018 rule said bump stocks are machineguns and ordered owners to destroy or turn them in. ATF had previously concluded bump stocks were not machineguns, but it changed course after the 2017 Las Vegas mass shooting. Cargill sued, arguing ATF lacked authority under the 1934 National Firearms Act definition of “machinegun.”
Reasoning
The Court had to decide whether a semiautomatic rifle fitted with a bump stock fires “automatically more than one shot . . . by a single function of the trigger,” the statute’s test. The majority concluded it does not: a bump stock only helps the shooter reset and reengage the trigger faster, and firing multiple rounds still requires separate trigger functions plus ongoing forward pressure. Because the device does not cause shots to fire “automatically” by a single trigger function, the rule exceeded ATF’s statutory authority.
Real world impact
The decision means ATF’s 2018 regulation is invalid and owners are not required under that rule to surrender or destroy bump stocks. The ruling limits ATF’s ability to reclassify popular accessories based solely on the agency’s interpretation of the 1934 statute. Congress can still change the law if it wants to ban or regulate bump stocks differently, and ATF could pursue other rulemaking or enforcement approaches consistent with the Court’s reading.
Dissents or concurrances
Justice Thomas wrote the opinion for the Court, joined by five other Justices; Justice Alito wrote a brief concurrence urging Congress to act. Justice Sotomayor dissented, joined by Justices Kagan and Jackson, arguing the ordinary meaning and purpose of the law cover bump stocks and that the decision weakens the statute’s force.
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