Garland v. Cargill
602 U.S. 406
SCOTUS2024Background
- The National Firearms Act (NFA) defines a "machinegun" as any weapon that can fire more than one shot automatically by a single function of the trigger, without manual reloading.
- Bump stocks are firearm accessories that enable semiautomatic rifles to fire at rates approaching machineguns by harnessing recoil for rapid trigger manipulation, but still require a separate trigger function for each shot.
- For years, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) viewed bump-stock-equipped semiautos as not qualifying as machineguns under the NFA.
- After the 2017 Las Vegas mass shooting, where bump stocks were used to devastating effect, ATF issued a rule reclassifying bump stocks as machineguns, mandating their destruction or surrender and threatening criminal penalties for possession.
- Michael Cargill surrendered his bump stocks under protest, then challenged ATF's rule in court as exceeding statutory authority; after trial and appeals, the Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does a bump stock make a semiautomatic a "machinegun"? | Bump stocks do not cause more than one shot per trigger function; thus, not machineguns. | Bump stocks allow continuous fire with one trigger pull, thus meeting the definition. | Bump stocks do not qualify as machineguns. |
| Meaning of "single function of the trigger" | Each shot still requires a separate trigger function, even with bump stocks. | Initiating rapid fire with a bump stock is a single pull/function, enabling continuous shots. | Each shot requires distinct trigger function. |
| Meaning of "automatically" in statute | Firing with bump stock is not automatic—it needs ongoing manual input (forward pressure). | Firing is automatic as bump stock harnesses recoil for repeated fire after one pull. | Not automatic; requires shooter input beyond trigger. |
| Scope of ATF's regulatory authority | ATF exceeded statutory authority; only Congress can amend the law to include bump stocks. | ATF's rule fits the purpose of the statute to ban weapons with high rates of fire. | ATF exceeded its statutory authority. |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (scope of headnotes and syllabi)
- Staples v. United States, 511 U.S. 600 (machinegun statutory interpretation based on trigger function)