Broughman v. Carver, 2010 U.S. App. LEXIS 23502

Broughman operated a Virginia gun shop under ATF dealer license and sold/assembled firearms.
During a 2006 ATF inspection, Carver found violations and concluded Broughman needed a manufacturer’s license.
Broughman challenged the finding; Carver’s findings were upheld by Carver’s supervisor.
Broughman obtained a manufacturer's license to continue operations and sued for declaratory relief.
The district court held Broughman’s activities fell within manufacturing under the GCA and granted summary judgment for ATF.
On appeal, the Fourth Circuit affirmed, ruling Broughman is a firearms manufacturer under the GCA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Broughman a manufacturer or dealer under the GCA?	Broughman contends dealer definition governs; manufacturer clause does not apply.	ATF argues overlapping both roles can exist; apply plain meaning.	Broughman is a manufacturer; district court affirmed.
Does the dealer definition render the manufacturer provision superfluous?	Specific dealer term controls; manufacturer term becomes null.	Overlap is permitted; both provisions valid and complementary.	Both dealer and manufacturer provisions apply; not superfluous.

Carbon Fuel Co. v. USX Corp., 100 F.3d 1124 (4th Cir. 1996) (plain meaning governs statutory interpretation)
Varity Corp. v. Howe, 516 U.S. 489 (S. Ct. 1996) (specific governs the general in some contexts)
United States v. Menasche, 348 U.S. 529 (1955) (duty to give effect to every clause and word)
Robinson v. Shell Oil Co., 519 U.S. 337 (1987) (interpret text in dominating general purpose)
New York v. Burger, 482 U.S. 691 (1987) (regulatory goals of licensing schemes)
Custer v. Sweeney, 89 F.3d 1156 (4th Cir. 1996) (GCA regulatory context and tracing system)
RSM, Inc. v. Buckles, 254 F.3d 61 (4th Cir. 2001) (ATF firearms tracing system interpretation)
United States v. Joshua, 607 F.3d 379 (4th Cir. 2010) (statutory interpretation de novo)