## Facts

- Louisiana officers executed a search warrant at Ernest Carol Camp’s home and seized firearms, illegal drugs, and drug-manufacturing equipment.
- One seized firearm was a semiautomatic rifle that Camp modified by adding an electrically operated trigger mechanism.
- When a switch located behind the original trigger was pulled, it supplied power to a motor connected to a fishing reel mounted inside the trigger guard.
- The motor rotated the reel, and the reel’s rotation repeatedly actuated the rifle’s original trigger in rapid succession.
- Once the switch was engaged, the rifle continued firing until the shooter released the switch or the ammunition was exhausted.
- ATF testing determined the weapon was capable of firing more than one shot without manual reloading by a single activating motion, including firing short bursts.

## Issues

1. Whether “trigger” in 26 U.S.C. § 5845(b) includes an added electrical switch that initiates a firing sequence resulting in automatic fire of multiple shots.
2. Whether a weapon that repeatedly actuates an original trigger through an external mechanism can qualify as a “machine gun” when the shooter performs only one initiating action.

## Decision

- The Fifth Circuit vacated the district court’s dismissal of the indictment and remanded for further proceedings.
- The court held that “trigger” in § 5845(b) is interpreted functionally and can include a switch that initiates the firing sequence.
- Because engaging the switch caused the rifle to fire automatically more than one shot without manual reloading, the modified rifle met the statutory definition of a machine gun.

## Legal Principles

- Under 26 U.S.C. § 5845(b), “trigger” is not limited to the firearm’s original mechanical lever; it includes any mechanism that initiates the firing sequence.
- A weapon “shoots … automatically more than one shot … by a single function of the trigger” when a single activating motion initiates continuous fire until the shooter stops it or ammunition is exhausted.
- Statutory interpretation should not permit easy circumvention of the machine-gun definition through add-on devices that convert semiautomatic firearms into automatic-firing weapons.

## Conclusion

The Fifth Circuit held that a switch that initiates an automatic firing sequence can be a “trigger” under § 5845(b), making a modified semiautomatic rifle a statutory machine gun when a single activation produces automatic multiple-shot fire.


United States v. Camp, 343 F.3d 743 (5th Cir. 2003)