United States v. Camp
United States Court of Appeals for the Fifth Circuit
343 F.3d 743 (2003)
Police searching Ernest Camp's (defendant's) home under a warrant found illegal drugs and a semiautomatic rifle he had modified with an electrical switch, motor, and fishing reel apparatus, which, once activated, allowed him to fire multiple rounds automatically by simply holding down the rifle's original trigger; an ATF agent testified the switch was not a legal "trigger activator" under agency regulations defining that term narrowly as a spring facilitating single-shot pulls. The trial judge nonetheless accepted Camp's argument that the switch was not itself a "trigger" under the federal machine gun statute and granted his motion to dismiss the charge, prompting the government's appeal.
Whether a homemade electrical device that a defendant installs and activates to convert a semiautomatic weapon into automatic fire constitutes the weapon's "trigger" for purposes of the federal statute defining a machine gun.