Garland v. Cargill

In Garland v. Cargill, the U.S. Supreme Court reviewed a Bureau of Alcohol, Tobacco, Firearms and Explosives rule that classified bump stocks as machineguns under the National Firearms Act. The rule was issued after the 2017 Las Vegas shooting. Michael Cargill, a gun owner, surrendered his bump stocks and sued, arguing the ATF exceeded its authority. On June 14, 2024, the Court held 6-3 that a semiautomatic rifle equipped with a bump stock does not fire more than one shot by a single function of the trigger, so it does not meet the statutory definition of a machinegun. The majority opinion by Justice Clarence Thomas emphasized that each trigger pull still fires one shot. The Court therefore invalidated the ATF rule, ruling that only Congress may ban bump stocks.

The Supreme Court ruled 6-3 that bump stocks are not machineguns; the ATF rule was struck down as exceeding statutory authority.

Whether a bump stock device converts a semiautomatic rifle into a "machinegun" under 26 U.S.C. § 5845(b), and whether the ATF had statutory authority to issue the ban.

The ruling reignited gun control debates, left bump stock regulation to Congress, and was seen as a significant check on executive agency rulemaking in firearms law.