Federal Machine Gun Ban is Constitutional, Sixth Circuit Says

A Tennessee man failed to convince a panel of Sixth Circuit judges that the federal ban on machine guns is unconstitutional.

Machine guns are dangerous weapons that aren’t commonly “possessed by law-abiding citizens for lawful purposes,” and a law that criminalizes their possession is therefore consistent with the tradition of firearm regulation in the country, the US Court of Appeals for the Sixth Circuit said Thursday.

Jaquan Bridges shot at a police car on a highway in Memphis, which led to a chase until he crashed. Officers searched his vehicle and found a handgun with a device attached, which allowed it to fire more than one round with a single trigger pull. The gun was examined and found to qualify as a machine gun under federal law.

Bridges was indicated on one count of possessing a machine gun, and a district judge rejected his constitutional argument in his bid to dismiss the charge. He was sentenced to nine months imprisonment.

Bridges argued the ban is unconstitutional under N.Y. State Rifle & Pistol Ass’n v. Bruen, in which the US Supreme Court held that firearm restrictions must be analogous to historical regulations in the US.

Appeals courts across the country have been hit with a wave of Second Amendment challenges to various federal and state gun laws in the wake of Bruen and last year’s high court ruling United States v. Rahimi.

Pre-Bruen, the Sixth Circuit in Hamblen v. United States held that the Second Amendment “categorically does not protect” carrying unregistered machine guns for personal use, Judge Richard Allen Griffin wrote Thursday.

The Hamblen court applied the Supreme Court’s 2008 ruling in District of Columbia v. Heller. Although Hamblen didn’t conduct a review of the text or history of firearm regulations, “it did not have to—it instead relied entirely on Heller’s clear statements, rooted in historical analysis, that applied to machineguns.” Bruen “did nothing to displace those aspects of Heller on which Hamblen relied,” Griffin said.

Even if Hamblen doesn’t control this case, Bridges’ constitutional challenge still fails, the court said.

Heller identified the historical tradition of banning dangerous and unusual weapons. And “regardless of whether we measure dangerousness by the weapon itself or the manner of possession, both were dangerous here,” Griffin wrote.

Bridges also admits that many machine guns are “owned unlawfully, in violation of a federal ban that has been in place for nearly four decades” in addition to several state bans. The history of unlawful machine gun use also supports a finding that they’re unusual under Heller, the judge said.

Judge John B. Nalbandian, concurring in part, wrote that he doesn’t “share the majority’s confidence” about how to understand dangerous and unusual weapons, and that the “historical record raises hard questions that haven’t been satisfactorily addressed.”

“Plain-error review and a facial analysis suffice to resolve this case without making broader pronouncements about machineguns and the history of ‘dangerous and unusual’ weapons,” Nalbandian said,

Judge Danny J. Boggs joined the majority.

The federal public defender’s office in Memphis represents Bridges.

The case is United States v. Bridges, 6th Cir., No. 24-05874, 8/7/25.