What Does the Supreme Court’s Bump Stock Decision Mean for For Forced Reset Triggers (FRT)?

If you’re reading this article and you aren’t already aware, last Friday the United States Supreme Court vacated ATF’s 2017 Rulemaking that banned bump stocks in Garland v. Cargill, No.22-976, (U.S. Supreme Court June 14, 2024). You can read my article about that decision here, but the quick summary is 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 it’s statutory authority by issuing a Rule that classifies bump stocks as machine guns. Slip Opinion, p. 6.

So what does this mean for the ongoing controversy over Forced Reset Triggers (FRTs)? Well, in the short-term, because the Supreme Court’s decision only specifically examined and applies to bump stocks, I don’t expect ATF to do an about-face and abandon the position that at least some FRT’s are actually machineguns. However, I think the reasoning applied by Justice Thomas is likely to (eventually) close the door on ATF’s machinegun argument.

The definition:

The term “machinegun” means any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger. The term shall also include the frame or receiver of any such weapon, any part designed and intended solely and exclusively, or combination of parts designed and intended, for use in converting a weapon into a machinegun, and any combination of parts from which a machinegun can be assembled if such parts are in the possession or under the control of a person. 26 U.S.C. § 5845(b)

The question we have to answer is, does a firearm equipped with a forced reset trigger shoot, automatically more that one shot, without manual reloading, by a single function of the trigger? No. First, like bump stocks, forced reset triggers

Justice Thomas spends about four pages of the Cargill opinion explaining the mechanical function of a typical semi-automatic rifle’s trigger. He concludes that the single function ends “when the shooter takes pressure off the trigger and allows it to move forward… the trigger mechanism is thereby reset to the original position.” Cargill, Slip Op. p. 11. Even though a forced reset trigger works differently than a bump stock, it still requires the trigger to reset before initiating a second function of the trigger to fire a second shot. As a result, FRT’s couldn’t meet the definition of a machinegun.

Even if a forced reset trigger did fire more than one shot in a single function of the trigger, it still wouldn’t constitute a machinegun, because, like with bump stocks, it does not do so automatically. In order to fire more than one shot automatically, it would require a single function of the trigger, “and then some.” Cargill, Slip Op. at 15 (quoting Guedes v. ATF, 920 F.3d 1, 44 (CADC 2019)(Henderson, J, concurring in part and dissenting in part)). For bump stocks, the “and then some” is application of the just right amount of forward pressure to make sure the rifle slides far enough back to reset, and far enough forward to bump fire. A shooter using a forced reset trigger has to walk a similar balancing act, applying enough rearward pressure to file, without applying too much and preventing the trigger from resetting.

As I explained above, it’s important to remember that the Supreme Court’s Cargill decision only specifically applies to bump stocks and is not immediately applicable to forced reset triggers. I believe the decision will have a significant impact on the outcome of litigation relating to forced reset triggers, but that impact won’t be immediate. AT least for the time being, ATF is still considering them machineguns

If you would like to discuss your forced reset triggers and your rights in light of this decision, contact FICG today to discuss your options.

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