Garland v. Cargill Revisions: 6/17/24

Background

A gun owner, Michael Cargill, surrendered two bump-stock accessories after the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) issued a 2018 rule treating bump stocks as “machineguns” and ordering owners to destroy or turn them in. ATF changed its long-standing guidance after the 2017 Las Vegas mass shooting, and Cargill sued, arguing the agency lacked power under the National Firearms Act’s definition of “machinegun.” Lower courts split, and the case reached the Supreme Court.

Reasoning

The Court asked whether a semiautomatic rifle with a bump stock shoots “automatically more than one shot…by a single function of the trigger.” It held that it does not. The Justices explained that each shot still requires the trigger to reset and that bump firing needs steady forward pressure from the shooter’s nontrigger hand. Because the weapon does not fire multiple shots by only a single trigger function and does not do so purely “automatically,” the Court concluded ATF exceeded its statutory authority in classifying bump stocks as machineguns.

Real world impact

The decision invalidates the 2018 ATF rule and relieves owners from the Rule’s surrender-or-destroy requirement under that regulation. The ruling leaves open the possibility that Congress could amend the law or that agencies might pursue different, lawfully grounded rules; it does not itself impose new criminal penalties.

Dissents or concurrances

A dissent argued bump stocks function like machineguns because a single activation plus maintained pressure produces continuous fire and emphasized congressional purpose and public safety concerns; a concurrence agreed with the text-based outcome.