Gun Owners of Am., Inc. v. Pamela Bondi -Western District of Michigan at Grand Rapids
Split Score
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This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The case concerns whether the Bureau of Alcohol, Tobacco, Firearms and Explosives was “substantially justified” in defending its 2018 rule classifying bump-stocks as machineguns, thereby defeating a fee request under the Equal Access to Justice Act. The Sixth Circuit held that, although the government ultimately lost on the merits in the Supreme Court, the agency’s position was reasonable in light of the widespread judicial disagreement and therefore affirmed the district court’s denial of attorney’s fees.
Circuit Split Identified
Legal Issue
Whether a semiautomatic rifle equipped with a bump-stock qualifies as a “machinegun” under 26 U.S.C. § 5845(b).
Circuit Positions
Bump-stock rifles are NOT machineguns – statutory text unambiguously excludes them
Bump-stock rifles ARE machineguns – defer to / adopt ATF interpretation
Conflict Summary
The Fifth and Sixth Circuits concluded that bump-stock–equipped rifles are NOT machineguns because each round still requires a separate mechanical function of the trigger, while the Tenth Circuit and the D.C. Circuit upheld the ATF’s contrary rule, agreeing that the bump-stock converts the rifle into a weapon that fires more than one shot automatically by a single trigger function.