As explained by Judge Murphy in Gun Owners of America, Inc. v. Garland, the best
reading of the statute is that Congress never gave the ATF "the power to expand the
law banning machine guns through [the] legislative shortcut" of the ATF's rule at issue
in this appeal, see Bump-Stock-Type Devices, 83 Fed. Reg. 66,514 (Dec. 26, 2018)
(the Rule). See 19 F.4th at 910 (Murphy, J., dissenting). Simply put, under the statute
as it currently reads, the addition of a bump stock to a rifle clearly does not make it
a machinegun.

Therefore, even accepting (as does the majority opinion) that the statute could reasonably
be read either way as to the legality of bump stocks, the statute must be read under
the rule of lenity to exclude a bump-stock rifle from the definition of a machinegun. See
United States v. Granderson, 511 U.S. 39, 54 (1994); Jones v. United States, 529
U.S. 848, 858 (2000) (if there are two possible "readings of what conduct Congress has
made a crime," the "harsher alternative" reading should be rejected because "Congress
should have spoken in language that is clear and definite") (quoting United States v.
Universal C.I.T. Credit Corp., 344 U.S. 218, 22122 (1952)). That is the import of the
majority's reasoning.