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The Hughes Amendment:
BATF interpreted the amendment as a prohibition on the civilian possession of any fully-automatic firearm manufactured after May 19, 1986.
After passage of the FOPA, a law-abiding Georgian named Farmer applied for the registration of a fully-automatic firearm manufactured after May 19, 1986, but his application was rejected by BATF.
Farmer contended that BATF's interpretation of the measure as a prohibition on possession of fully-automatic firearms manufactured after May 19, 1986 was incorrect, since the law exempted fully-automatic firearms newly-manufactured under the authority of the United States, thus it would exempt firearms approved for registration by BATF.
The U.S. District Court of the Northern District of Georgia ruled in Farmer's favor. On appeal by the federal government, the Court of Appeals for the Eleventh Circuit reversed the decision with respect to BATF's interpretation
Court decisions invalidating parts of the National Firearms Act:
Rock Island Armory was charged with manufacturing "machineguns" in 1987 and 1988 in violation of the registration requirements of the National Firearms Act. In U. S. v. Rock Island Armory, Inc. (773 F. Supp. 117, C.D. Ill. 1991), the chief judge of the U.S. District Court for the Central District of Illinois dismissed those charges because the NFA sections upon which they were based were "without any constitutional basis." The judge noted that the Supreme Court had previously ruled that the NFA's registration requirement was constitutional only because it was enacted for the purpose of facilitating the collection of tax revenue. Thus, he concluded, because the Hughes Amendment had been interpreted as prohibiting the possession of fully-automatic firearms manufactured after May 19, 1986, the NFA's registration requirement no longer served its tax collection purpose. The judge said that since "Congress has no enumerated power to require registration of firearms," the constitutional basis for the NFA registration provision no longer existed. The government initiated an appeal of the decision, but later requested that the appeal be dismissed, thus the Rock Island decision stands. In U.S. v. Dalton (960 F.2d 121, 10th Cir. 1992), the U.S. Court of Appeals for the 10th Circuit adopted the Rock Island precedent.