A couple of years ago, a man named Jaquan Bridges took a wild ride through Memphis that quickly became a headline-grabbing police chase. This isn’t extremely uncommon, but his situation was unique: it sparked a legal battle that could shape gun rights for years to come. His case landed in the Sixth Circuit, and Bridges found himself the center of a major fight over whether federal law can ban machine guns.
Bridges Switches Things Up
Bridges was driving on a Tennessee highway in 2023 when things took a dangerous turn. He almost hit a police car, which led officers to try and pull him over. Instead of stopping, Bridges slowed down, rolled down his window, and fired several gunshots at the police vehicle. One bullet actually struck the car and came close to hitting an officer in the head.
After that, Bridges sped off, triggering a high-speed chase through the city. The pursuit ended only when he crashed his car into a concrete barrier. Bridges crawled out of the wrecked vehicle and was quickly arrested by the police. When officers searched his car, they found a loaded Glock 23 handgun with an attached “switch.” This is a device that turns a regular pistol into a machine gun by allowing it to fire multiple rounds with one pull of the trigger (not to be confused with the similar bump stock).
Lawmakers Lay Down the Line
The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) later confirmed that this modified Glock qualified as a machine gun under federal law. Bridges did not have legal registration for the weapon and did not dispute that it met the definition of a machine gun.
18 U.S.C. § 922(o) is a federal law that makes it illegal for most people to possess or transfer a machine gun. The statute says:
(1) Except as provided in paragraph (2), it shall be unlawful for any person to transfer or possess a machinegun.
(2) This prohibition does not apply to: (A) transfers to or possession by or under the authority of the United States or any department or agency thereof, or a State, or a department, agency, or political subdivision of a State; or (B) any lawful transfer or lawful possession of a machinegun that was lawfully possessed before May 19, 1986.
In short, unless you’re law enforcement, military, or you owned the machine gun before May 19, 1986, you can’t legally have one. The law is part of the federal government’s effort to keep fully automatic weapons out of civilian hands.
Bridges Brings in Bruen
A grand jury indicted Bridges on one count of possessing a machine gun under 18 U.S.C. § 922(o). He fought back. Bridges argued that the law itself was unconstitutional, both on its face and as applied to Bridges.
Bridges leaned heavily on recent Supreme Court decisions about gun rights, especially New York State Rifle & Pistol Ass’n v. Bruen. That 2022 case changed how courts look at Second Amendment challenges. Instead of asking if a law serves a good government purpose (like keeping people safe), Bruen said courts should focus on whether the law fits with America’s historical tradition of regulating firearms.
Bridges argued that under Bruen’s new approach, the ban on machine guns doesn’t hold up. He claimed there isn’t enough historical evidence showing that Americans have traditionally banned private ownership of weapons like machine guns. He also said the law unfairly restricts his individual right to keep and bear arms, as protected by the Second Amendment.
In short, Bridges wanted the court to take a fresh look at § 922(o) through Bruen’s lens. The district court reviewed his arguments but ultimately disagreed. Bridges chose to plead guilty to possessing the machine gun and was sentenced to 108 months in prison. He appealed to the Sixth Circuit.
Heller and Hamblen Hurdles
To win a facial challenge, Bridges had to show that the law was not valid under any circumstances.
The appellate court started by reviewing precedent. A big one was the 2008 case District of Columbia v. Heller, where the U.S. Supreme Court said the Second Amendment doesn’t protect “dangerous and unusual weapons” and specifically mentioned that banning machine guns like M-16 rifles would be allowed. On top of that, Hamblen v. United States (decided by the Sixth Circuit a year after Heller) held that the Second Amendment does not give individuals the right to own unregistered machine guns for personal use.
Bridges had tried to argue that things had changed since those cases because of SCOTUS’s more recent decision in Bruen. The Sixth Circuit said that even after Bruen, Hamblen was still good law. That meant § 922(o) didn’t violate the Second Amendment (either on its face or as applied to Bridges) because machine guns are not protected arms under the Second Amendment. The court explained that Heller and Hamblen already did the historical work and found a tradition of banning “dangerous and unusual weapons.” Since machine guns fit that category, Congress can ban them.
'Dangerous and Unusual'
But the court didn’t stop there. It also did its own fresh analysis using Bruen’s two-step approach. First, it agreed that “arms” in the Second Amendment covers all bearable weapons (including machine guns) even if they didn’t exist at the founding. So, Bridges’s conduct was presumptively protected.
Next, it looked at history. The key question: are machine guns “dangerous and unusual,” meaning not typically owned by law-abiding citizens for lawful purposes? It may be a no-brainer that the court found that machine guns are extremely dangerous. After all, they can fire hundreds of rounds per minute and are designed for military use or crime, not self-defense. They’re also “unusual” because very few civilians legally own them (only those grandfathered in before 1986), and most are in police hands or owned illegally.
The court looked at old laws and cases about weapon bans. They found a long tradition of regulating or banning weapons mainly used for crime or violence as opposed to self-defense or ordinary lawful purposes. Machine guns fit this pattern perfectly.
So, even under Bruen’s new standard, the court concluded that § 922(o) lines up with America’s tradition of regulating dangerous and unusual weapons. That means the law is constitutional on its face; it doesn’t violate anyone’s Second Amendment rights just by existing.
Bridges’ Bid Loses
But what about the argument that the law was unconstitutional as it had been applied to Bridges, specifically? The court rejected that, too.
The judges explained that both facial and as-applied challenges fail for the same reasons. They pointed out that the law applies to everyone who possesses a machine gun illegally, and Bridges’s conduct was exactly the kind lawmakers wanted to prevent. In short, the Second Amendment does not protect possession of machine guns by individuals, no matter the circumstances.
Impact on Future Cases
It’s worth noting that Judge Nalbandian, who wrote a separate concurring opinion, did take a step back to reflect on the bigger picture. He pointed out that while he agreed Bridges’s conviction should stand, there are still “weightier historical questions” about gun bans that weren’t fully settled in this case. He flagged that future cases might need to dig deeper into the history of “dangerous and unusual weapons,” especially when it comes to newer types of firearms or different circumstances.
Nalbandian also cautioned against reading this decision as the final word on all Second Amendment issues related to machine guns or other weapons. He encouraged courts and lawyers to give “history and tradition the attention it requires—and deserves” next time a similar challenge comes up. So, while the ruling answers the question for Bridges, it leaves the door open for more debate about gun laws in the future.
Related Resources:
- Supreme Court Denies Challenge to Law Prohibiting Guns for People Under Restraining Orders (FindLaw's Federal Courts)
- SCOTUS Upholds Ghost Gun Regulations (FindLaw's Federal Courts)
- Who Are 'the People' Entitled to Bear Arms Under the Second Amendment? (FindLaw's Federal Courts)
