Garland v. Cargill

Overview

(U.S. Supreme Court, June 14, 2024) By a 6-3 vote, the Supreme Court invalidated the federal Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) rule that classified bump stocks as “machine guns” for purposes of the National Firearms Act, which would have essentially prohibited ownership of the devices. The Court held that “a bump stock—an accessory for a semi-automatic rifle that allows the shooter to rapidly reengage the trigger (and therefore achieve a high rate of fire)” — does not turn the rifle into a machine gun as defined by federal law. The decision was not based on the Second Amendment and did not apply the Bruen test; rather, the opinion is solely based on the Court’s interpretation of the National Firearms Act’s definition of machine gun. The Court drew the distinction between the definition of machine gun, automatically firing more than one shot by a single function of the trigger, and how a bump stocks work on semi-automatic rifles, using the gun’s recoil to help rapidly and repeatedly pull the gun trigger. Because ATF based its rule on the Agency’s statutory authority to regulate machine guns, the Court concluded ATF exceeded its statutory authority and invalidated the rule. Read the full opinion here.  

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