Garland v. Cargill
United States Supreme Court
602 U.S. 406, 144 S. Ct. 1613 (2024)
- Written by Jamie Milne, JD
Facts
Historically, the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) consistently affirmed that semiautomatic firearms, even those equipped with bump stocks, did not qualify as machine guns under the National Firearms Act of 1934. However, after a shooter used semiautomatic rifles with bump stocks to rapidly fire hundreds of shots at a Las Vegas crowd, killing 58 people and wounding hundreds, ATF amended its rules to classify bump stocks as machine guns. Bump-stock owners were required to destroy their bump stocks or surrender them to ATF within 90 days. Michael Cargill (plaintiff) surrendered two bump stocks under protest and then sued Attorney General Merrick Garland, ATF, and other government parties (defendants). Cargill argued that under the Administrative Procedure Act, ATF lacked authority to adopt the rule because semiautomatic firearms with bump stocks did not meet the statutory definition for machine guns. The district court held in ATF’s favor, but the Fifth Circuit reversed, finding that the statutory definition was ambiguous and that the rule of lenity required that the ambiguity be resolved in Cargill’s favor. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Thomas, J.)
Concurrence (Alito, J.)
Dissent (Sotomayor, J.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.