Hardin v. Bureau of Alcohol, Tobacco, Firearms and Explosives

Summary

The Sixth Circuit held that the definition of "machinegun" under the National Firearms Act is ambiguous as applied to bump stocks, declined to apply Chevron deference because the statutory scheme is predominantly criminal, and applied the rule of lenity to resolve the ambiguity in favor of the plaintiff, thus reversing the ATF's rule banning bump stocks as machinegun parts. The court emphasized that Congress, not the ATF, must amend the statute if bump stocks are to be prohibited.

Holdings

1. The statutory definition of 'machinegun' is ambiguous as applied to bump stocks because reasonable jurists have reached diametrically opposed conclusions and the ATF itself has flip-flopped on the issue.
2. Chevron deference is not warranted because the statutory scheme is predominantly criminal in scope and the ATF lacks special expertise in criminal law.
3. Because the statute is ambiguous and Chevron deference does not apply, the rule of lenity requires resolving the ambiguity in Hardin's favor, so the ATF's rule exceeds its statutory authority.

Questions Presented

1. Whether the statutory definition of 'machinegun' under the National Firearms Act unambiguously includes bump stocks.
2. If the statute is ambiguous, whether Chevron deference applies to the ATF's interpretation.
3. Whether the rule of lenity requires resolving any ambiguity in favor of Hardin.

Disposition

reversed_and_remanded