Key Takeaways
- Supreme Court Ruling Limits ATF Authority: In Garland v. Cargill (602 U.S. 406), the Supreme Court held that bump stocks do not meet the statutory definition of "machine guns" under the National Firearms Act of 1934, thus invalidating the ATF's ban on these devices.
- Textualist Interpretation Prevails: The majority opinion, authored by Justice Thomas, emphasized a strict, textualist reading of the statute, determining that only Congress—not federal agencies—can expand the legal definition of "machine gun."
- Nationwide Impact on Firearms Regulation: The decision immediately impacts federal regulation of bump stocks in 35 states lacking their own bans, and sets a precedent limiting administrative agency power to reinterpret criminal statutes.
Introduction
Garland v. Cargill is a landmark United States Supreme Court case that reshaped the federal regulatory landscape for firearm accessories, particularly bump stocks. At its core, the case examined whether the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) had the statutory authority to classify bump stocks as "machine guns" under the National Firearms Act of 1934 (NFA). The Court’s decision, issued in June 2024, vacated the ATF’s rule banning bump stocks, finding that the agency had exceeded its delegated authority. This guide provides a comprehensive analysis of the case, its background, the legal arguments presented, the Supreme Court's reasoning, and the broader implications for gun regulation and administrative law.
For the full Supreme Court opinion, see the official PDF. For case details and analysis, see SCOTUSblog and Oyez.
Background of the Case
What Are Bump Stocks?
Bump stocks are firearm accessories designed to harness the recoil energy of a semi-automatic rifle, enabling the shooter to fire at a rate similar to that of a fully automatic weapon. While the trigger is still technically pulled for each shot, the mechanism allows for rapid succession, blurring the line between semi-automatic and automatic fire. The legal status of bump stocks became a national issue following their use in the 2017 Las Vegas mass shooting, which resulted in heightened scrutiny and calls for regulation.
The ATF’s Regulatory Action
In response to public outcry and political pressure, the ATF issued a final rule in 2018 classifying bump stocks as "machine guns" under the NFA. This rule required owners to destroy or surrender their bump stocks or face criminal prosecution. The ATF’s interpretation marked a significant shift from its previous position, which had not treated bump stocks as machine guns. The rule’s justification relied on the argument that bump stocks enabled a firearm to "shoot, automatically more than one shot, without manual reloading, by a single function of the trigger," thus meeting the statutory definition.
Michael Cargill’s Challenge
Michael Cargill, the plaintiff, surrendered two bump stocks under protest to comply with the ATF’s rule. He subsequently filed suit against Attorney General Merrick Garland, the ATF, and other federal officials, arguing that the ATF lacked statutory authority to classify bump stocks as machine guns. The case wound its way through the federal courts, with Cargill contending that only Congress could expand the statutory definition and that the ATF’s rule was an overreach.
Procedural History
Lower Court Proceedings
The case began in the United States District Court for the Western District of Texas, which upheld the ATF’s rule. The Fifth Circuit Court of Appeals, however, reversed, holding that the statutory definition of "machine gun" did not encompass bump stocks and that the ATF’s rule was invalid. This created a circuit split, as other circuits had upheld the rule, prompting the Supreme Court to grant certiorari.
Supreme Court Review
The Supreme Court heard oral arguments in February 2024. The central question was whether the ATF's interpretation of the NFA was permissible, and whether the agency had the authority to criminalize possession of bump stocks by administrative rulemaking. The case attracted significant attention from gun rights advocates, regulatory agencies, and constitutional scholars.
For case information and oral argument transcripts, see the Supreme Court docket.
Legal Issues Presented
Statutory Interpretation: The National Firearms Act
The case hinged on the interpretation of the NFA’s definition of a "machine gun," which reads:
“Any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger.”
The key legal issue was whether a bump stock-equipped semi-automatic rifle fits this definition. The ATF argued that the device effectively allows a single trigger pull to fire multiple rounds automatically, while Cargill and his supporters contended that each shot still requires a separate trigger function.
Agency Authority and the Administrative Procedure Act
Another central issue was the scope of the ATF’s regulatory authority. Under the Administrative Procedure Act (APA), agencies are empowered to interpret and enforce statutes, but only within the boundaries set by Congress. The case questioned whether the ATF had overstepped its authority by redefining a criminal statute through rulemaking.
Chevron Deference and Its Limits
The doctrine of Chevron deference, established in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), traditionally grants agencies leeway in interpreting ambiguous statutes. However, the Supreme Court in Garland v. Cargill declined to defer to the ATF’s interpretation, signaling a shift in how courts may approach agency interpretations of criminal statutes.
The Supreme Court’s Decision
The Majority Opinion
Justice Clarence Thomas authored the majority opinion, joined by Chief Justice Roberts and Justices Alito, Gorsuch, Kavanaugh, and Barrett. The Court held that bump stocks do not meet the statutory definition of "machine gun" because the firearm’s trigger must reset and be engaged separately for each shot, even when a bump stock is used. The opinion emphasized a strict textual interpretation of the statute, stating that:
“A semiautomatic rifle equipped with a bump stock does not fire more than one shot ‘by a single function of the trigger.’”
The Court also underscored that the ATF’s rule criminalized conduct that Congress had not expressly prohibited, which is impermissible under the separation of powers.
The Dissent
Justice Sonia Sotomayor authored a dissenting opinion, joined by Justices Kagan and Jackson. The dissent argued that the functional reality of bump stocks—allowing a shooter to fire at a rate indistinguishable from a machine gun—should inform the statutory interpretation. The dissenters warned that the majority’s narrow reading undermines the legislative intent to regulate rapid-fire weapons and endangers public safety.
The Decision’s Immediate Effect
The Supreme Court’s ruling invalidated the ATF’s ban on bump stocks, effectively legalizing their possession in the 35 states that do not have independent state-level bans. The decision also set a precedent restricting the ability of federal agencies to reinterpret criminal statutes without clear congressional authorization.
Analysis of the Court’s Reasoning
Textualism and Statutory Construction
The majority’s decision is a quintessential example of textualist statutory interpretation. Justice Thomas focused on the plain meaning of the words “single function of the trigger,” concluding that a bump stock does not alter the basic operation of a semi-automatic firearm. The Court rejected arguments based on policy or legislative history, holding that criminal statutes must be construed strictly and that ambiguity should be resolved in favor of the defendant.
Limiting Agency Power
The ruling places significant limits on the power of federal agencies to expand the scope of criminal liability through rulemaking. The Court reiterated that only Congress has the authority to define federal crimes, and agencies cannot use regulations to create new criminal offenses. This aspect of the decision reflects a growing skepticism of broad administrative authority, particularly in the context of criminal law.
Implications for Chevron Deference
While the Court did not explicitly overturn Chevron deference, it declined to apply it to the ATF’s interpretation of the NFA. This signals a narrowing of Chevron’s reach, especially in criminal contexts, and suggests that agencies may face greater judicial scrutiny when interpreting statutes that carry criminal penalties.
Broader Legal and Policy Implications
Impact on Federal Firearms Regulation
The immediate impact of the decision is the invalidation of the federal bump stock ban. In the absence of congressional action, bump stocks are now legal under federal law in most states. However, the ruling does not affect state-level bans, and several states continue to prohibit bump stocks independently.
Precedent for Agency Authority
Garland v. Cargill sets a significant precedent for the limits of agency authority. The decision may embolden challenges to other regulatory actions where agencies are perceived as exceeding their statutory mandates, particularly in the realm of firearms and other contentious issues.
Second Amendment Considerations
Although the case was decided on statutory grounds, not constitutional ones, many observers view the decision as a victory for gun rights advocates. The ruling underscores the importance of legislative clarity in gun regulation and may influence future legal battles over the Second Amendment and related statutes.
Legislative Response
The Supreme Court’s decision places the onus on Congress to clarify or amend the statutory definition of "machine gun" if it wishes to regulate bump stocks or similar devices. Legislative efforts to address the issue have been proposed in the past, but have not yet been enacted.
Practical Effects and Next Steps
For Gun Owners
Gun owners in the 35 states without state-level bump stock bans are no longer subject to federal criminal penalties for possessing these devices. However, they should remain vigilant about local and state laws, which may still prohibit bump stocks. Owners who surrendered bump stocks under the now-invalidated federal rule may seek legal redress, but the path for compensation or return of property is uncertain.
For Attorneys and Legal Practitioners
Attorneys advising clients on firearms law must carefully navigate the interplay between federal, state, and local regulations. The decision in Garland v. Cargill highlights the importance of statutory language and the limits of agency power. Legal practitioners should monitor legislative developments and potential challenges to other agency rules in light of this precedent.
For Policymakers
Policymakers seeking to regulate bump stocks or similar devices must now do so through clear legislative action. The Supreme Court’s decision leaves little room for agencies to act unilaterally in the absence of explicit statutory authority.
Conclusion
Garland v. Cargill represents a major development in the regulation of firearms and the scope of administrative agency authority. The Supreme Court’s decision to vacate the ATF’s bump stock ban underscores the importance of legislative clarity, strict statutory interpretation, and the separation of powers. The ruling has immediate effects on the legality of bump stocks in much of the United States and sets a precedent for future challenges to agency rulemaking in the criminal context.
For further reading, consult the official Supreme Court opinion, SCOTUSblog case file, and Oyez case summary.
Disclaimer: This guide provides a general overview of Garland v. Cargill and is not legal advice. The case involves complex statutory and constitutional issues, and there may be nuances or subsequent developments not covered here. For specific legal guidance, consult a qualified attorney or use resources like Counsel Stack.
