The 'accessory' gambit: Why 11th
Circuit's mechanical logic fails 2A

In the recently published decision of United States v. Alsenat (2026), the Eleventh Circuit Court of Appeals affirmed a conviction involving Machine Gun Conversion Devices (MCDs), specifically "Glock switches." The panel rested its holding on the claim that machineguns are not protected arms in common lawful use. However, the district court also accepted the government's fallback theory that unattached conversion devices are mere "accessories" or "accoutrements," not protected "Arms."

That accessory framing should alarm gun owners.

To the casual observer, this may seem like a minor semantic point. To a firearm attorney, it is a transparent attempt to deconstruct the Second Amendment by its parts.

As one of the attorneys who represented the Buckeye Firearms Association in our successful suit against the city of Cincinnati regarding their bump stock ban, I have seen this "accessory gambit" before. It failed in Ohio, and it should fail in the federal courts as well. …