https://www.supremecourt.gov/Docket...2162648893_2021-11-22 Aposhian cert reply.pdf
Throughout the history of this case, from ATF’s
promulgation of the bump-stock regulation as a final rule in 2018 through the government’s defense of the
rule in the court of appeals (and three other circuits), the government has argued that the rule simply gives
effect to the best reading of the unambiguous statutory language and that the agency, therefore, neither wants nor is entitled to deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984).
So too here. The government emphasizes in its opposition to the Petition that “neither Petitioner
nor the government accepts the premise that the final rule was an exercise of delegated authority to resolve
a statutory ambiguity.” BIO 15.