Update (how ya been? I missed you.)

I wasn't able to upload last week as I've been super buried helping to write institutional comments on the frame or receiver and pistol brace rulemakings. I'm really sorry! More uploads are coming very soon, but for now, I thought you guys might enjoy these snippets from my drafts:

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One of many unprecedented and constitutionally suspect changes to the American legal system in the New Deal era, the National Firearms Act of 1934 (“NFA”) identified and severely regulated several classes of arms. It is well known that, in its original drafts, the NFA intended to impose “near-prohibitory controls on…handguns.” Towards that end, the Act regulated short or cut-down rifles and shotguns in an attempt to prevent an end-run around the handgun tax. This treatment of “pistols and revolvers” was eventually removed, but the regulations on other short firearms remained: a vestigial, twitching dewclaw of a failed attempt to erase the handgun from American life.

Of course, that leaves us where we are today: our nation’s highest Court has recognized that handguns―the shortest, most concealable firearms of all―lie at the very core of Second Amendment protection, in part due to the commonality of their use. Now the ATF, seemingly spurned by the commonality of use of a class of handguns, appears to endeavor to to treat them as regulable “Short Barreled Rifles” (“SBR”s), a class whose divination was to―it bears repeating―prevent people from creating the functional equivalent of handguns from long guns.

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Further, the word “circumvent” is itself problematic. To “circumvent” is to “find a way around (an obstacle).” “Violate,” on the other hand, is to “break or fail to comply with (a rule or formal agreement).” In common parlance, then, to “circumvent” a law is more similar in concept to “narrow compliance” than a violation. Narrow compliance, of course, is what most would call “following the law.” We have thoroughly reviewed the statutes at issue and cannot find therein a source of argument for the contention that ATF is tasked with punishing individuals endeavoring to comply with the law.