Garland v. Cargill
602 U.S. 406 (2024)
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Rule of Law:
A semiautomatic rifle equipped with a bump stock is not a “machinegun” under 26 U.S.C. § 5845(b) because it does not enable the weapon to fire more than one shot “by a single function of the trigger,” and it does not do so “automatically.”
Facts:
- The National Firearms Act defines a “machinegun” as a weapon that can shoot “automatically more than one shot… by a single function of the trigger.”
- A bump stock is an accessory for a semiautomatic rifle that replaces the standard stock and is designed to help the shooter use the firearm's recoil to fire shots in rapid succession.
- For many years, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) consistently concluded that bump stocks did not convert semiautomatic rifles into machineguns.
- In October 2017, a gunman used semiautomatic rifles fitted with bump stocks in a mass shooting in Las Vegas, Nevada.
- Following the Las Vegas shooting, the ATF reversed its long-standing position and issued a new rule classifying bump stocks as machineguns.
- The final rule required owners of bump stocks to either destroy them or surrender them to the ATF to avoid criminal prosecution.
- Michael Cargill, a Texas resident who owned two bump stocks, surrendered his devices to the ATF under protest.
Procedural Posture:
- Michael Cargill filed suit against the ATF in the U.S. District Court for the Western District of Texas, challenging the final rule.
- Following a bench trial, the District Court entered judgment in favor of the ATF.
- Cargill (appellant) appealed the decision to the U.S. Court of Appeals for the Fifth Circuit.
- A three-judge panel of the Fifth Circuit initially affirmed the District Court's judgment.
- The Fifth Circuit then granted a rehearing en banc, where the full court reversed the District Court's judgment, siding with Cargill.
- The government (petitioner) sought and was granted a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does a semiautomatic rifle equipped with a bump stock qualify as a “machinegun” under 26 U.S.C. § 5845(b)?
Opinions:
Majority - Justice Thomas
No. A semiautomatic rifle equipped with a bump stock is not a “machinegun” as defined by federal statute. The statute requires that a weapon fire more than one shot “by a single function of the trigger.” A rifle with a bump stock does not meet this definition because the trigger must still be released and reengaged for every single shot. The bump stock merely accelerates the rate at which these separate trigger functions occur; it does not eliminate them. Each bump of the trigger against the shooter's finger is a new and distinct function. Furthermore, even if it were considered a single function, the weapon would not fire “automatically,” because it requires continuous and specific manual input from the shooter—maintaining forward pressure on the rifle's front grip—which is an action separate from the function of the trigger itself. This is distinct from a true machinegun where continuous fire results from a single pull and hold of the trigger.
Concurring - Justice Alito
The statutory text is clear and must be followed. While the Congress that enacted the original statute likely would not have seen a material difference between a traditional machinegun and a rifle with a bump stock, the Court's role is to interpret the law as written, not as it might have been written. The 2017 Las Vegas shooting highlighted the need to amend the law but did not change the meaning of the existing statutory text. The simple remedy for this issue lies with Congress, which can amend the law to explicitly include devices like bump stocks.
Dissenting - Justice Sotomayor
Yes. A bump-stock-equipped semiautomatic rifle is a machinegun under the plain meaning of the statute. The phrase “single function of the trigger” should be understood from the shooter’s perspective as the single action that initiates a continuous firing sequence. By pulling the trigger once and maintaining forward pressure, the shooter engages in a single action to produce continuous fire, which is the hallmark of a machinegun. The bump stock automates the process of firing multiple shots by harnessing the rifle's recoil energy. The majority's hyper-technical focus on the internal mechanics of the firearm, rather than its function and effect, creates an artificial loophole that circumvents Congress's clear intent to heavily regulate weapons capable of mass destruction. When an object walks, swims, and quacks like a duck, it should be called a duck.
Analysis:
This decision represents a significant victory for the textualist approach to statutory interpretation, emphasizing the precise wording of a statute over its perceived purpose, even in the face of public safety concerns. The ruling invalidates the ATF's 2018 Final Rule, effectively legalizing bump stocks at the federal level unless Congress enacts new legislation. The case reinforces the principle that administrative agencies cannot radically reinterpret long-standing statutes to address new technological developments or policy challenges; that power rests with Congress. This precedent will likely constrain agencies from broadly interpreting other statutes in the future, particularly in politically charged areas like firearms regulation.
