United States v. George Dodson, III, 519 F. App'x 344

Dodson sold AR-15 drop-in auto sears before and after 1981; ATF Ruling 81-4 classified auto sears as machineguns under the NFA.
Dodson believed pre-1981 auto sears were exempt and continued selling thousands for decades.
In 2011 a grand jury charged Dodson with unlawful possession/transfer of machineguns and related offenses; he pled guilty to unlawful transfer.
The district court treated pre-1981 auto sears as within the machinegun ban and applied multiple sentencing enhancements.
The ATF retroactivity issue centered on whether Ruling 81-4 could exempt pre-1981 weapons from later criminal controls while allowing post-1981 regulation.
Three grease guns with altered serial numbers were restored; the district court found the restorability sufficient for the enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retroactivity of ATF Ruling 81-4 to pre-1981 auto sears	Dodson	United States	Ruling retroactivity limited; exemptions apply prospectively, not fully exempting pre-reg items.
Mistake-of-law and good-faith-reliance defenses at sentencing	Dodson	United States	No clear error to refuse these defenses; district court reasonably weighed 3553(a) factors.
Readily restorable standard for obliterated serials enhancement	Dodson	United States	Grease guns readily restorable; enhancement properly applied.
Mitigating factors at sentencing	Dodson	United States	Court properly departed downward; sentence deemed reasonable.

United States v. Catchings, 708 F.3d 710 (6th Cir. 2013) (review of guidelines de novo; factual findings for clear error)
Gall v. United States, 552 U.S. 38 (S. Ct. 2007) (abuse-of-discretion standard for reasonableness; presumption for within-range sentences)
Staples v. United States, 511 U.S. 600 (S. Ct. 1994) (willfulness not required where strict liability offense applies)
United States v. Balint, 258 U.S. 250 (1922) (dangerous weapons; knowledge not required for offense)