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Project Curia
Supreme Court decisions
No. 22-976Jun 14, 2024Crime and Law EnforcementReversed

The question

Whether a semiautomatic rifle equipped with a bump stock qualifies as a "machinegun" under 26 U.S.C. § 5845(b), such that ATF could classify bump stocks as machineguns by rule.

Garland v. Cargill

What the Court decided

The Court reversed and held that ATF exceeded its statutory authority when it issued a Rule classifying bump stocks as machineguns. A semiautomatic rifle equipped with a bump stock does not fire more than one shot by a single function of the trigger, because the trigger must still be released and reset between each shot. Even if it did, it would not do so automatically. A bump stock only reduces the time that elapses between separate functions of the trigger.

How the justices split

6-3
In favor 6Against 3
Thomas
Roberts
Alito
Gorsuch
Kavanaugh
Barrett
Sotomayor
Kagan
Jackson

The Court's opinion

Thomas, joined by Roberts, Alito, Gorsuch, Kavanaugh, Barrett

The statute defines a machinegun as a weapon that fires more than one shot by a single function of the trigger, automatically. A semiautomatic rifle with a bump stock fails both requirements. The phrase function of the trigger refers to the trigger's mode of action, and with a bump stock the trigger must still be released and reset before each shot, so each shot is a separate function of the trigger. A bump stock only reduces the time between those functions. Even if a single function of the trigger produced multiple shots, the weapon would not fire automatically. ATF therefore exceeded its statutory authority.

Concurring

Alito, writing alone

Alito filed a concurring opinion.

Dissenting

Sotomayor, joined by Kagan, Jackson

Sotomayor filed a dissenting opinion, joined by Kagan and Jackson.

How we know · 5 sourced claims
  • The Court held that ATF exceeded its statutory authority by issuing a Rule that classifies a bump stock as a machinegun under 26 U.S.C. § 5845(b).

    Source: syllabus, Held

  • A semiautomatic rifle equipped with a bump stock does not fire more than one shot by a single function of the trigger, because the shooter must release and reset the trigger between every shot.

    Source: syllabus, Held

  • Even if a bump-stock-equipped rifle could fire more than one shot by a single function of the trigger, it would not do so automatically.

    Source: syllabus, Held

  • Thomas delivered the opinion of the Court, joined by Roberts, Alito, Gorsuch, Kavanaugh, and Barrett.

    Source: syllabus, lineup

  • Sotomayor filed a dissenting opinion, joined by Kagan and Jackson.

    Source: syllabus, lineup

Read the opinion on supremecourt.gov