Thompson/Center Arms and The Supreme Court
In the case of United States v. Thompson/Center Arms Co. (1992), the U.S. Supreme Court ruled in the company's favor by deciding that the rifle conversion kit that Thompson sold for their pistols did not constitute a short-barreled rifle under the National Firearms Act of 1934.
The Bureau of Alcohol, Tobacco, and Firearms contended that the mere possession of a pistol having a barrel less than sixteen inches (406 mm) long, a shoulder stock, and a rifle-length (more than sixteen inches) barrel constituted constructive intent to "make" an illegal short-barreled rifle (SBR) (by combining the pistol's frame, the pistol-length barrel, and the shoulder stock) even if the shoulder stock was intended to be used only with the rifle-length barrel.
The Supreme Court disagreed and its decision clarified the meaning of the term "make" in the National Firearms Act by stating that the mere possession of components that theoretically could be assembled in an illegal configuration was not in itself a violation as long as the components could also be assembled into a legal configuration.
One argument raised was the example of ammonium-nitrate fertilizer and Diesel oil, which can very often be found together in a farmer's possession (fertilizer for the crops, fuel for the tractor.) Both are lawful, and while they can easily be assembled into the high explosive known as ANFO, possession of both has never been held to imply (without other evidence) that a farmer was "making" explosives.
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