Garland v. Cargill
 | |
| Garland v. Cargill | |
| Term: 2023 | |
| Important Dates | |
| Argued: February 28, 2024 Decided: June 14, 2024 | |
| Outcome | |
| affirmed | |
| Vote | |
| 6-3 | |
| Majority | |
| Clarence Thomas • Chief Justice John Roberts • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett | |
| Concurring | |
| Samuel Alito | |
| Dissenting | |
| Sonia Sotomayor • Elena Kagan • Ketanji Brown Jackson | |
Garland v. Cargill is a U.S. Supreme Court case decided 6-3 on June 14, 2024, challenging the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives' (ATF) authority to issue a rule banning bump stocks. The Supreme Court held that bump stocks do not meet the definition of a machine gun and that the ATF exceeded its statutory authority in issuing the rule.
The case was argued before the Supreme Court of the United States on February 28, 2024, during the court's October 2023-2024 term.[1]
The case came on a writ of certiorari to the United States Court of Appeals for the Fifth Circuit. To review the lower court's opinion, click here.
Why it matters: The court’s decision in the case limited the ATF’s statutory authority to classify bump stocks as machine guns under the National Firearms Act and ended the federal ban on bump stocks.
Timeline
The following timeline details key events in this case:
- June 14, 2024: The U.S. Supreme Court affirmed the decision of the United States Court of Appeals for the Fifth Circuit.
- February 28, 2024: The U.S. Supreme Court heard oral argument.
- November 3, 2023: The U.S. Supreme Court agreed to hear the case.
- April 6, 2023: Merrick Garland appealed to the U.S. Supreme Court.
- January 6, 2023: The United States Court of Appeals for the Fifth Circuit reversed the lower court's decision, stating that a bump stock should be excluded from the definition of a "machine gun." The court stressed that it is Congress' responsibility to pass legislation banning such an accessory, and that the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) did not have the authority to enact such a regulation without approval from Congress.
Background
| Administrative State |
|---|
|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
- See also: Chevron deference
Following guidance issued by President Donald Trump (R) in 2018, the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) changed its interpretation of the Gun Control Act and the National Firearms Act to find that bump stocks qualify as machine guns and can therefore be prohibited.[2][3]
Gun owners and organizations challenged the rule, arguing in multiple lawsuits that the agency lacked the authority under federal law to issue the rule. Three appellate courts upheld the ban and the U.S. Supreme Court declined to reconsider the decisions—leaving in place a district court ruling that applied Chevron deference to the ATF’s changed interpretation of the law.[4][3]
The case was appealed to the United States Court of Appeals for the Fifth Circuit which ruled that ATF exceeded its statutory authority when it adopted the rule. The court departed from prior appellate court reasoning on the issue and declined to apply Chevron deference to the agency’s changed interpretation of the underlying statutes. The majority concluded in part that the imposition of criminal penalties by a federal agency prompted the rule of lenity to supersede Chevron deference.[2][3]
SCOTUS agreed to hear the case in the October 2023-2024 term.
Questions presented
The petitioner presented the following questions to the court:[5]
Questions presented:
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Oral argument
Audio
Audio of oral argument:[7]
Transcript
Transcript of oral argument:[8]
Outcome
The court ruled 6-3 that the ATF exceeded its statutory authority when issuing a rule to ban bump stock devices. It affirmed the United States Court of Appeals for the Fifth Circuit ruling.
Justice Clarence Thomas delivered the opinion of the court, joined by Chief Justice John Roberts and Justices Samuel Alito, Neil Gorsuch, Brett Kavanaugh and Amy Coney Barrett. Justice Samuel Alito filed a concurring opinion. Justice Sonia Sotomayor filed a dissenting opinion, joined by Justices Elena Kagan and Ketanji Brown Jackson.[1]
Opinion
Opinion of the court
Justice Clarence Thomas delivered the opinion of the court, which argued that semiautomatic rifles equipped with bump stocks do not meet the definition of a machine gun under the National Firearms Act. Thomas argued that the ATF exceeded its statutory authority by issuing the 2018 rule to ban bump stocks:[9]
| “ |
Section 5845(b) defines a ‘machinegun’ as any weapon capable of firing ‘automatically more than one shot . . . by a single function of the trigger.’ We hold that a semiautomatic rifle equipped with a bump stock is not a ‘machinegun’ because it cannot fire more than one shot ‘by a single function of the trigger.’ And, even if it could, it would not do so ‘automatically.’ ATF therefore exceeded its statutory authority by issuing a Rule that classifies bump stocks as machineguns.[6] |
” |
Concurring opinion
Justice Samuel Alito filed a concurring opinion, arguing that Congress can amend the laws surrounding bump stocks and machine guns to address concerns surrounding the topic:[9]
| “ |
The horrible shooting spree in Las Vegas in 2017 did not change the statutory text or its meaning. That event demonstrated that a semiautomatic rifle with a bump stock can have the same lethal effect as a machinegun, and it thus strengthened the case for amending §5845(b).
But an event that highlights the need to amend a law does not itself change the law’s meaning. There is a simple remedy for the disparate treatment of bump stocks and machineguns. Congress can amend the law—and perhaps would have done so already if ATF had stuck with its earlier interpretation. Now that the situation is clear, Congress can act.[6] |
” |
Dissenting opinion
Justice Sonia Sotomayor filed a dissenting opinion, joined by Justices Elena Kagan and Ketanji Brown Jackson. She argued against the court’s interpretation of the statute and posited that bump stocks meet the statute’s definition of a machine gun:[9]
| “ |
This is not a hard case. All of the textual evidence points to the same interpretation. A bump-stock-equipped semiautomatic rifle is a machinegun because (1) with a single pull of the trigger, a shooter can (2) fire continuous shots without any human input beyond maintaining forward pressure. The majority looks to the internal mechanism that initiates fire, rather than the human act of the shooter’s initial pull, to hold that a ‘single function of the trigger’ means a reset of the trigger mechanism. Its interpretation requires six diagrams and an animation to decipher the meaning of the statutory text. See ante, at 8–11, and n. 5. Then, shifting focus from the internal mechanism of the gun to the perspective of the shooter, the majority holds that continuous forward pressure is too much human input for bump-stock-enabled continuous fire to be ‘automatic.’ See ante, at 14–17.
The majority’s reading flies in the face of this Court’s standard tools of statutory interpretation. By casting aside the statute’s ordinary meaning both at the time of its enactment and today, the majority eviscerates Congress’s regulation of machineguns and enables gun users and manufacturers to circumvent federal law.[6] |
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Text of the opinion
Read the full opinion here.
Commentary about the case
Pre-decision commentary
Law professor Stephen I. Vladeck argued about what he viewed as potential implications of the Garland v. Cargill decision on future administrative agency action: “Although the specific legal issue before the justices reduces to the technical question of whether a bump stock thus converts a semiautomatic rifle into a ‘machine gun,’ Garland v. Cargill is a much broader illustration of—and referendum on—the real-world implications of the Court’s mounting hostility toward federal administrative agencies. That’s because the real question in Cargill is not whether a rifle with a bump stock counts as a machine gun; the real question is whether we’re ready for a world in which that question will be resolved not by an expert executive-branch agency that answers directly to the president, but by federal judges who answer to no one.”[10]
Philip Hamburger, founder of the New Civil Liberties Alliance, argued about what he viewed as the merits of the case: “During the Trump administration, the bump stock ban cropped up as a rather glaring example of unlawful administrative power. … This rule turned half a million people into felons overnight. That’s not a power that the Constitution gives to administrative agencies — so it deserved a lawsuit,” according to The New York Times.[11]
Post-decision commentary
Senator Cory Booker (D-N.J.) released a statement following the decision in Garland v. Cargill arguing, “The Supreme Court’s radical decision today to strike down the federal ban on bump stocks will make Americans less safe from gun violence and mass shootings, period. … Elected leaders have the ability to protect Americans from senseless and preventable gun violence tragedies. Congress must act to reverse this ruling, and I urge the Senate to take up legislation to ban bump stocks and protect our communities. We owe it to the victims of Las Vegas and to every community plagued by gun violence to take decisive action now.”[12]
Eric Tirschwell, executive director of the organization Everytown Law, released a statement against the SCOTUS ruling arguing, “Today, the Supreme Court failed to right the Fifth Circuit’s wrong, putting millions at risk of harm. It remains our belief that the ATF had the authority to categorize bump stocks as machine guns and keep them out of our communities. … Machine guns – guns capable of automatic firing – have been tightly regulated under federal law since the 1930s, and bump stocks and other conversion devices are designed to skirt the law and mimic automatic gunfire. This decision by the high court is dangerous and wrong. The ATF must be undeterred in continuing to aggressively enforce our nation’s gun laws.”[13]
The editorial board for The Wall Street Journal published an opinion piece supporting the SCOTUS decision and its impact on the administrative state: “This is an especially important message in an era when regulators in both parties have decided they can rewrite laws regardless of the plain language of a statute. In this and other cases, the Supreme Court has been saying loud and clear that regulators can’t exceed their authority—and that Congress needs to get back in the business of debating and writing laws rather than ducking difficult votes in favor of the administrative state.”[14]
Dan McLaughlin, a writer for The National Review, supported the SCOTUS decision and argued against Justice Sonia Sotomayor’s reasoning in her dissent: “Sotomayor tried to call out the majority for preferring the statutory definition to what she claimed was the more common use of the words in the statute, but as Thomas noted, the Court before has concluded that ‘when Congress takes the trouble to define the terms it uses, a court must respect its definitions as virtually conclusive. … This Court will not deviate from an express statutory definition merely because it varies from the term’s ordinary meaning.’”[15]
Impact
The decision in Garland v. Cargill limited the statutory authority of the ATF to amend the definition of what is classified as a machine gun. The court ruled that the ATF had exceeded its statutory authority and nullified the agency’s rule banning bump stocks.
October term 2023-2024
The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[16]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Garland v. Cargill (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Garland v. Cargill
Footnotes
- ↑ 1.0 1.1 SCOTUSblog, "Garland v. Cargill," accessed November 16, 2023
- ↑ 2.0 2.1 SCOTUSblog, "Whether 'bump stocks' are 'machineguns,' and a very specific arbitration issue," November 1, 2023
- ↑ 3.0 3.1 3.2 SCOTUSblog, "Justices take up bump stock dispute," November 3, 2023
- ↑ SCOTUSblog, "Government seeks review of federal gun regulations on domestic abusers, bump stocks," April 23, 2023
- ↑ [1]
- ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ https://www.supremecourt.gov/oral_arguments/audio/2023/22-976 Supreme Court of the United States, "Oral Argument - Audio," argued February 28, 2024]
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued February 28, 2024
- ↑ 9.0 9.1 9.2 Justia, "Garland v. Cargill, 602 U.S. _ (2024)," accessed June 14, 2024
- ↑ The Atlantic, "The Bump-Stocks Case Is About Something Far Bigger Than Gun Regulations," March 13, 2024
- ↑ The New York Times, "In Fight Over Bump Stock Ban, Lawyers Take Aim at Administrative State," February 28, 2024
- ↑ Cory Booker, "Booker Statement on Supreme Court Decision Striking Down Federal Ban on Bump Stocks," June 14, 2024
- ↑ Everytown, "Everytown Responds to Supreme Court's Cargill Decision Striking Down ATF Rule Prohibiting Bump Stocks," June 14, 2024
- ↑ Wall Street Journal, "The Supreme Court's Welcome Bump Stock Ruling," June 14, 2024
- ↑ [https://www.nationalreview.com/2024/06/the-logical-fallacies-of-sotomayors-bump-stock-dissent/ National Review, "The Logical Fallacies of Sotomayor's Bump-Stock Dissent," June 14, 2024]
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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