1998 muzzleloading court case

[LAR-15]

RESOLUTION OF MODERN MUZZLE
LOADING COURT CASE
ATF has received a favorable decision in the case
Modern Muzzleloading, Inc. v. Magaw, No. 97-
2956 (TAF) (D.D.C. Aug. 8, 1988).
This case involved a challenge to ATF’s
classification of plaintiff’s Knight Disc Rifle as a
“firearm” for purposes of the Gun Control Act.
The Knight Disc Rifle is an in-line modern
muzzle loading rifle, which interchangeably uses
either a percussion cap or a shotgun primer as an
ignition system. Plaintiff claims the Knight Disc
Rifle should be classified as an “antique firearm”
and not regulated as a “firearm” under the Gun
Control Act.
The District Court held that ATF properly
classified the Knight Disc Rifle as firearms since
it utilizes a modern centerfire shotgun primer, not
an antique ignition system. The Court rejected
plaintiff’s argument that because the Gun Control
Act is a criminal statute; the rule of lenity must
apply. Rather, the court held that ATF’s
classification decision is entitled to deference and
is neither arbitrary nor capricious.

 

[LAR-15]

MODERN MUZZLELOADING
ISSUES
The Omnibus Appropriations Act for 1999,
effective October 21, 1998, amends the definition
of antique firearm under the provisions of The
Gun Control Act (GCA), 18 U.S.C. § 921(a)(16),
to include certain muzzle loading firearms. This
amendment will result in the exemption of the
Knight Disc Rifle and other in line muzzle
loading rifles that do not incorporate a firearm
frame or receiver from regulation under the GCA.
Accordingly the Knight Disc Rifle and such
would no longer need to be shown in your acquisition
and disposition record, nor is an ATF Form
4473 or NICS check required at the time of sale.
Records of sales of this firearm made prior to
October 21, 1998 should be retained with your
records since the GCA covered it until that date.

 

[Gildas]

Case decided Aug 7th 1998
Omnibus Appropriations Act for 1999 signed into law October 21st 1998

That was pretty fast work!