What no one ever told you about the S&W agreement,3 part article

ernest2

New member
source = http://communities.prodigy.net/sportsrec/jeffsnyder.html#top

Part 1 of 3 parts

What No One Bothered To Tell You
About The Smith & Wesson Settlement
by Jeff Snyder

--------------------------------------------------------------------------------
[An abridged version of this article appears in the July-August 2000 issue of American Handgunner magazine, published by Publishers Development Corporation. The full-length version is presented here for the first time, with the publisher's and author's permission.]

--------------------------------------------------------------------------------


Section Menu

• Safety standards

• Ban on cheap,
concealable handguns

• Ban on large
capacity magazines
and assault weapons

• Dealer requirements

• More gun control

• Registration and
ballistic fingerprinting

• Helping sell
gun control

• Cost of guns and
used gun sales

• Endgame

Smith & Wesson, the nation's largest handgun manufacturer, has become the first company to fall to the federal, state and local governments' litigation campaign against gun manufacturers. On March 17, it entered into an agreement imposing sweeping restrictions on the design, marketing and distribution of firearms with the Department of Treasury, the Department of Housing and Urban Development, and various state and city governments. The agreement was entered into in settlement of several lawsuits and in exchange for an agreement by other state and local governments not to bring suit on similar grounds. HUD, Treasury, and various cities are now putting intense pressure on Glock and other handgun manufacturers to sign the agreement. It's bare-knuckle coercion. Upon hearing of Glock's refusal to sign the agreement, New York Attorney General Elliot Spitzer warned the company that "If you do not sign, your bankruptcy lawyers will be knocking at your door."

The S&W Settlement Agreement has dire implications for the remnant of the right to keep and bear arms. Unfortunately, blatant and massive incursions upon the Bill of Rights, along with record high peace-time taxation and Presidents who bomb people in far away places (i.e., kill them) in order to divert attention from personal problems at home, do not seem to excite much attention these days, so perhaps it is also necessary to point out that the agreement represents a new paradigm for regulation of business that, from government's perspective, simply offers too many benefits not to be used again and again. Yes! Should your industry be targeted next, it will certainly limit how much money you can make!

Mainstream reporting on the actual contents of the agreement has been minimal, focusing primarily on the new safety requirements for firearms, and the fact that dealers will not be able to sell firearms at gun shows unless all purchasers are subject to background checks. The agreement goes far beyond this, however, imposing significant restrictions long sought by gun control activists, including a ban on selling cheap, concealable handguns and a requirement that gun buyers first take a safety course, and substantially expands existing federal gun control laws. But more importantly, if the major gun manufacturers can be pressured to sign this agreement, it will successfully nationalize the operations of the gun industry, controlling manufacturing and design, distribution and sales and, to a lesser extent, advertising and marketing. Not surprisingly, then, the agreement also presses manufacturers and dealers into service as adjuncts to law enforcement. Manufacturers and dealers will become government informants.

Because the agreement is a contract negotiated in settlement of litigation, all this has been achieved in a manner that entirely circumvents the legislative process (i.e., representative government) at both federal and state levels. What is perhaps more remarkable, however, is that the agreement also goes very far toward bypassing Constitutional review.

A federal law, of course, is subject to challenge in the courts on the grounds that it violates some provision of the Bill of Rights or is unconstitutional because it exceeds the legislative powers of Congress. In recent years the Supreme Court has struck down gun control legislation, namely, the Gun-Free School Zone Act and various parts of the Brady Act, on the grounds that the acts exceeded the legislative powers granted to Congress. The S&W agreement, however, is fairly beyond Constitutional review because it is a contract among the parties. First, with the notable exception of Congress itself, which might challenge the agreement as a usurpation of its legislative authority, it is highly unlikely that anyone other than the actual parties to the agreement will have standing to bring the suit.

Second, it is very unclear to what extent a party such as S&W can seek to avoid obligations it has contractually agreed to on the grounds that the obligations, if imposed by act of Congress or state legislature, would be unenforceable violations of a fundamental right (like the Second Amendment) or would be beyond Congress' legislative power. Just as a person can voluntarily waive his Fourth Amendment rights by consenting to a search, it is likely that a person can agree to waive his Constitutional rights by contract with the government. As a result, the S&W agreement may well be Constitutionally unreviewable. Stated otherwise, the government's power under the agreement may freely exceed all Constitutional limits, and the power may be exercised privately and extra-legally.

As if to drive this point home, the S&W agreement creates, sui generis, a new regulatory body, the "Oversight Commission," to implement the agreement and conduct inspections of participating manufacturers and dealers. The Commission is composed of 5 members: two appointed by the city and county parties to the agreement, one appointed by the state parties, one appointed by the manufacturer parties and one by the ATF. Action is by majority rule. The Commission and its staff are funded by the various parties to the agreement, but the maximum amount a manufacturer can be compelled to pay is $25,000 annually.

The Commission possesses large, undefined discretionary authority in carrying out the purpose of the agreement. This, perhaps, is nothing new, since many Congressional grants of authority to federal regulatory agencies are broad and ill-defined. What is particularly noteworthy about this new regulatory body, though, is that the mixed composition of the Commission renders it virtually unaccountable to any particular political entity or constituency. Unlike the federal alphabet agencies which remain, at least theoretically, subject to Congressional oversight and thus are only one step removed from the electorate, here is a powerful, new regulatory agency made up of persons appointed from four different levels of government (city, county, state and federal), three of whom are appointed by groups of governments, and thus removed from direct accountability to Congress, the President, any particular state legislature, governor, mayor, or electoral group. It is simply impossible for the people, by coordinating their efforts, to exercise even an indirect control over the composition and hence the action taken by this Commission. This is pure private making of public policy and constitutes a seismic transformation of representational government.

The S&W agreement thus represents, even more fundamentally than the tobacco company settlement, a startling new method of autocratic, non-reviewable and extra-legal regulation by the executive branches of government that controls the fundamental operations of an entire industry: design and manufacturing standards, advertising, distribution and sales. The fact that it has been done to an industry that significantly affects the ability of individuals to exercise one of their fundamental rights, listed second only to the free exercise of religion, speech and assembly, should raise alarms from all civil libertarians and adherents to constitutional, representational government.

To understand the magnitude of the agreement's accomplishments, you must have some knowledge of what the agreement says and how it works within the context of existing firearms laws. Spend a little time on this, and behold the face of your government.

Safety standards

Within 24 months, each firearm made by S&W and any other manufacturer who joins the agreement must have "a built-in, on-board locking system, by which the firearm can only be operated with a key or combination or other mechanism unique to that gun." The manufacturer must commit 2 percent of annual firearm sales revenues to the development of a technology that recognizes only authorized users, which must be incorporated in all new firearm designs in 36 months. However, if the eight firearms manufacturers and importers with the largest U.S. firearms sales volume agree to incorporate this technology in all firearms, then all manufacturers who are parties to the agreement must do so. In other words, at that point, all manufacturers who are parties to the agreement will have to cease making firearms without the authorized user technology.

Each firearm must be designed so that it "cannot be readily operated by a child under the age of 6." This can be accomplished by making trigger pull strength in double action mode exceed 10 pounds, designing the firing mechanism so that an average 5 year old's hands would be too small to operate the gun, or "requiring multiple, sequenced actions in order to fire the gun."

Depending on how far this and the other safety requirements are taken, these alterations may seriously compromise the usefulness or reliability of a handgun for self-defense purposes. Having to fumble with a complex lock can cost precious seconds that may mean the difference between life and death. As a further example, it is possible that more revolvers and pistols will be designed to fire only in double action mode, which requires a much stronger trigger pull because the pull both cocks and then releases the hammer. As most handgun owners know, the strength of trigger pull dramatically affects accuracy because compressing the trigger against strong resistance can cause the gun to twist in the hand (i.e, the muzzle will move off target as you squeeze). Overcoming this obstacle requires hand strength and serious training, and clearly imposes a greater hardship on women, who generally have smaller, weaker hands than men.

The proof, though, that these standards may compromise usefulness lies within the agreement itself. The military and law enforcement are entitled to acquire guns without the new safety features by filing for an exemption.

Ban on cheap, concealable handguns
The agreement requires firearms to have a barrel length of at least 3 inches, unless the gun passes certain accuracy tests. All guns must pass certain "drop tests" and performance tests, including reliability and test firing with "proof cartridges" that generate excess pressure and test metal strength. These requirements do not appear onerous for quality firearms, but will very likely eliminate many cheaper, less well made guns. In addition, the height of a pistol must be at least 4 inches and the length at least 6 inches unless, again, the firearm meets certain accuracy standards. Continued next page…


[This message has been edited by ernest2 (edited June 23, 2000).]

[This message has been edited by ernest2 (edited June 23, 2000).]
 
Source =
http://communities.prodigy.net/sportsrec/jeffsnyder.html#top

Continuing The Gun Zone Exclusive by Jeff Snyder… Part 2 of 3


What No One Bothered To Tell You
About The Smith & Wesson Settlement - II
--------------------------------------------------------------------------------


Section Menu

• Ban on large capacity magazines and assault weapons
• Dealer requirements
• More gun control
• Registration and ballistic fingerprinting
• Helping sell gun control
• Cost of guns and used gun sales
• Endgame

Piece it all together and you will see that in one stroke the Clinton administration has just achieved a national ban on "cheap, concealable," generally low-caliber weapons, sometimes known as "Saturday-Night Specials," something that no administration has ever been able to get out of Congress, and which most gun control advocates have never been able to get out of state legislatures. Gun control advocates often claim that these guns are disproportionately used by criminals. (Query: if true, wouldn't we prefer that criminals use cheap, unreliable, inaccurate handguns? Do we really want them to step up to quality, larger caliber firearms?) However, they are often all that poorer citizens who live in dangerous neighborhoods can afford for protection.

But, you say, not all manufacturers will sign the agreement, so the "ban" is full of loopholes. Not so. If the major gun manufacturers sign on to this agreement, the ban will be near complete because of the provisions of the agreement imposing dealer codes of conduct. A dealer cannot be an authorized dealer if he does not abide by the terms of the agreement. If the major gun manufacturers sign onto the agreement and the dealer wants to have an actual business selling the guns everyone wants (Smith & Wesson, Glock, Ruger, Beretta, etc.), he will not be able to sell Saturday Night Specials made by anyone.

Ban on large capacity magazines and assault weapons
Manufacturers who sign the agreement may not sell magazines that accept more than 10 rounds, and any pistol model designed after January 1, 2000 must be designed so that it cannot accept magazines made prior to September 14, 1994 (the date the federal assault weapon ban was signed into law). Dealers who want to be "authorized dealers" must agree to not sell any magazines that are capable of holding more than 10 rounds, even those that are legal because manufactured prior to September 14, 1994. In addition, in order to become an authorized dealer of S&W or any other manufacturer who becomes a party to the agreement, the dealer must agree not to sell any "semi-automatic assault weapons" as defined in the federal assault weapon ban.

Now the 1994 federal assault weapon ban sunsets in 2004. Its prohibitions cease to be effective unless the law is renewed by act of Congress. The S&W agreement, then, has just made the ban on semi-automatic assault weapons and large capacity magazines permanent, avoided the risk of Congress' failure to renew the law and in fact made Congressional action irrelevant. In addition, by restricting the ability of authorized dealers to sell large capacity magazines, the agreement goes much further than current law and significantly restricts the market for the still legal, grandfathered supply of pre-ban large capacity magazines.

"So what", or "Oh, good," you say. Then please try this thought experiment. Imaginatively place yourself in the following situation, which some of your fellow citizens had the great misfortune of actually experiencing. You are a Korean grocer in South Central L.A. during the Rodney King riots and are faced with an angry mob of ten, twenty or fifty persons who want to rob and trash your store and quite possibly kill you and the members of your family who are also there. All that stands between you and this fate is a semiautomatic AK-47 knockoff that you hold in your hands. The police will not come into the neighborhood to quell the riot because --- and this is rich --- it's too dangerous! ("To serve and protect" has its limits!) Query: how many rounds should your magazine be able to hold? Might not the sight of a "semiautomatic assault weapon" with a large, protruding magazine holding 30 rounds provide a deterrent effect that avoids bloodshed on either side?

Dealer requirements
The agreement prohibits the manufacturer from selling to any but authorized dealers and distributors, and dealers or distributors may become authorized only by agreeing to adhere to numerous requirements. Some of these have the effect of further eliminating the number of federal firearms licensees who are only "casual" dealers, because they will not have the volume of business to support the new costs of doing business imposed by the agreement. The overall effect of these provisions is to consolidate the industry into a much smaller, more controllable group whose entire livelihood depends on keeping government officials happy.

In this group are the requirements that dealers carry at least $1 million of liability insurance, that all firearms be secured in "a locked fireproof safe or vault " other than during business hours, that dealers keep firearms in locked display cases during business hours except to show a firearm to a customer, and pass a "comprehensive written exam, which shall be developed by the manufacturers in consultation with ATF and approved by the Oversight Commission." In addition, all employees must participate in annual training sessions developed by the manufacturers and similarly approved.

Authorized dealers are also required to maintain an electronic inventory tracking system which records the make, model, caliber or gauge and serial number of all firearms that they acquire. They must keep the federal firearm purchase forms in a secure fireproof location on the business premises and perform an inventory check once a month and maintain the results of the report in a secure location. If an inventory audit reveals any firearms that cannot be accounted for, the dealer faces the loss of the right to continue selling the manufacturer's firearms.

Finally, the manufacturers are required to "encourage their authorized dealers to consent to up to three unannounced ATF compliance inspections each year." Current law permits one, but evidently this is deemed an insufficient waiver of Fourth Amendment rights by Treasury, state and local governments.

More gun control
The dealer requirements impose three other substantive gun control restrictions. First, dealers pledge not to transfer any firearm prior to receiving notice from NICS, the federal background check system. Current law permits dealers to complete a sale if they have not received notice within three days. This "loophole" in the Brady Act was specifically built in by Congress to assure gun owners that NICS could never be used as a means to indefinitely restrict legitimate gun sales and to assure dealers that they would not be forced out of business waiting for the federal government to complete their sales. The agreement simply overrides this judgment of Congress. No sales until the government declares that the buyer is permitted to purchase a firearm.

This permits the federal government to implement a discretionary de facto waiting period, because the sale cannot take place until the government gets around to completing the background check. Similarly, if NICS is shut down during a period of "national emergency," no sales may occur at all. It little matters that the authority for these delaying tactics may not exist. The dealers and purchasing customers will have little remedy or recourse for them.

Next, the dealers agree that they will not sell or transfer firearms to individuals unless they "have demonstrated that they can safely handle and store firearms through completion of a certified firearms safety training course or by having a certified firearms safety examination." You will not be able to buy a gun unless you first prove you have taken an approved safety course. The agreement contains no specifications of the content of the course or the duration of the training. These matters are left to the Oversight Commission. Regardless of how benign, however, the requirement effectively imposes a new waiting period for gun buyers that can take weeks to months depending on the availability of approved training courses and the frequency of approved safety examinations. It is likely that the safety course requirement will make maters much worse for women in abusive relationships who need a gun for protection now, and not later. Note also, the immediate effect on firearms dealers. They will be able to sell no guns (rifles, shotguns and handguns) at all until the Oversight Commission announces the qualifications for "safety courses," and then will have to wait even longer while their customers go get the necessary certificates, a process that could easily take six months to years to build up a critical mass.

Registration and ballistic fingerprinting
The agreement requires manufacturers who sign the agreement and their authorized dealers to cooperate with law enforcement, including by participating "in ATF's Access 2000 program to facilitate electronic linkage to their inventory system to allow for rapid responses to ATF's firearms trace requests." Now it makes no sense to trace a firearm used in a crime and recovered by the ATF against unsold firearms sitting in the dealer's inventory. The ATF linkage to dealer tracking systems makes sense only if the system also records to whom firearms formerly in the dealer's inventory were sold. So guess what the ATF and the Oversight Commission have in mind, especially in light of the following: the agreement requires authorized dealers to "provide law enforcement, government regulators conducting compliance inspections, and the Oversight Commission . . . for any authorized purpose, full access to any document related to the acquisition and disposition of firearms deemed necessary by one of those parties."

While the agreement itself does not specify that the dealer's inventory tracking systems link the disposition of a firearm to a named individual, it is naive to believe that dealers who must cooperate with law enforcement will not be compelled to maintain this information in their systems, accessible to the manufacturer, Oversight Committee and the ATF, particularly because dealers face penalties and loss of their dealership if they cannot account for firearm dispositions and prove that they are bona fide. The agreement thus has the de facto effect of creating a de-centralized, but nonetheless accessible registration database for firearm purchases, and transforms dealers and manufacturers into government informants.

Within 6 months, if technologically available, the manufacturers who are parties to the agreement must also fire each firearm they sell before sale and enter the digital image of the expended casing along with the weapon's serial number into a system compatible with the National Integrated Ballistics Identification Network System. The agreement thus facilitates the creation of a national "ballistics fingerprinting" database for all new guns sold. Concluded next page…
---------------------------------------------

[This message has been edited by ernest2 (edited June 23, 2000).]
 
http://communities.prodigy.net/sportsrec/jeffsnyder.html#top

Part 3 of 3

Concluding The Gun Zone Exclusive by Jeff Snyder…


What No One Bothered To Tell You
About The Smith & Wesson Settlement - III
--------------------------------------------------------------------------------


Section Menu

• Cost of guns and
used gun sales

• Endgame

Helping sell gun control
Gun manufacturers who sign the agreement are required to help work for more gun control! The agreement provides that parties to the agreement "will work together to support legislative efforts to reduce firearms misuse." Further, they must also fund anti-gun public service announcements! The manufacturers who sign the agreement must contribute 1 percent of their annual firearms revenues to a trust fund that will conduct a "public service campaign to inform the public about the risk of firearms misuse, safe storage, and the need to dispose of firearms responsibly." The agreement does not require that these public-spirited messages be balanced with messages informing us about the dangers of not owning and being able to use a gun, even though that, too, can cost lives.

Cost of guns and used gun sales
It should be obvious that the manufacturer and dealer costs of complying with these new requirements will drive the price of firearms up, probably significantly. Consider just two facts. Manufacturers are losing three percent of their gross revenues out of the gate for the development of authorized user technology and the education trust fund. That cost will be passed along to customers. Guns which incorporate the new authorized user technology will also be notably more expensive.

The increased cost of new guns will create a higher demand for used guns. People who want a gun without the "safety features" that render the guns somewhat less than optimal for self-defense will also prefer to acquire used guns. Thus, the price of used guns will also rise. Put that together with the bans on cheap, low quality firearms contained in the agreement and the cost of taking an approved safety course in order to buy, and the result is that a fair number of Americans are going to be priced out of the (legal) market and that fewer guns will be sold. It is legitimate to wonder whether the agreement might not spur the growth of a black market for guns.

Unfortunately, matters are even worse. The agreement contains a regrettable lack of specificity regarding the extent to which dealers may sell guns that do not comply with the safety requirements. Forgive the lawyerly analysis, but in an era in which we can expect government officials to push the envelope as long as there is "no controlling legal authority," it is not idle speculation. The agreement provides that to become an authorized dealer, a dealer must agree in writing to "sell only firearms that comport with the design criteria of this Agreement" (emphasis supplied). These standards include the requirements that the guns have a second hidden serial number and within 24 months have an external on-board locking device. You see the problem. This requirement does not contain a qualification that clearly permits dealers to sell guns which were manufactured prior to the dates that the agreement requires the new safety features. It is thus very possible to argue that authorized dealers cannot sell any guns manufactured by anyone prior to the date that guns are required to contain the second serial number (60 days from the date of the agreement).

This interpretation, which is certainly available to the Oversight Commission, is a disaster both for citizens and the gun industry. Such a restriction would substantially curtail gun sales and drive more dealers out of business because many people trade in old guns in order to buy new and many can only afford used guns. Used guns could still be sold privately. However, gun control activists have long wanted to close the Brady Act loophole that exists for private sales by requiring that these be conducted through the intermediary of a licensed gun dealer so that background checks can be performed. If that restriction is passed, the existing gun stock would become untransferrable. In other words, no legal market for used guns.

Endgame
The foregoing observations assume that most of the major manufacturers can be compelled to sign on to the Agreement. There is some possibility, of course, that that won't happen, and that S&W will end up as the only manufacturer party to the agreement. Incredible pressure is being brought to bear to insure that others sign up, however. Within a week of the settlement, Bloomberg was reporting that 29 U.S. cities and counties representing, according to HUD Secretary Andrew Cuomo, 20 to 30 percent of all gun purchases, had pledged to favor companies that followed the agreement's gun-safety standards when buying guns for law enforcement. Senator Charles Schumer has reported that he will sponsor legislation that will mandate similar weapons-purchasing preferences by the federal government. Those who refuse to toe the line thus not only face continuing crushing litigation from HUD, cities, counties and states across the United States, but also the threat of loss of large contracts that sustain their business.

The prognosis is not good. While not every gun manufacturer will become party to this agreement, once most of the larger ones have signed up, it will have a critical mass that will be hard to resist. At that point the industry itself will have an incentive to lobby for laws that foreclose anyone else operating on a different basis, to eliminate the competitive advantage possessed by "outsiders" who could produce lower cost guns without the safety features. The "voluntary" agreements by the manufacturers will provide necessary political cover to Congress to pass laws extending the agreement's requirements by making them law. No one should be allowed to sell unsafe guns!

As bad as all this is, the long term effects of the agreement are even worse. The most critical accomplishment of the agreement is that it defines a new standard of what is acceptable civic responsibility with regard to the ownership of firearms. The nation's existing stock of over 200 million guns has just been established as unsafe and unacceptably prone to misuse by unauthorized users. The internal logic of the new regulatory regime leads naturally and fairly predictably to the conclusion that these guns must be phased out of use. Within the next 5 to 10 years, then, expect the following: existing ownership of the "unsafe" guns will probably be grandfathered, but transfer will be subject to draconian restrictions or outright prohibition. Very likely, the owner's estate will be required to destroy the weapons, turn them in or render them useless relics upon death, so that they may not be transferred to future generations.

This, then, is the fairly predictable result of the S&W agreement: complete destruction of the country's existing firearms stock of over 200 million guns within a generation. Back to square one on the acquisition of firearms under a system that prices poorer citizens out of the legal market and by and large tracks ownership. Impossible? Federal, state and local governments have just implemented radical, major national restrictions on firearms, including a ban on cheap, concealable weapons and the institution of a requirement of safety training before buying a gun, and extended existing federal laws. They have created a basis for nationalization of the operations of an entire industry, to be controlled by a regulatory body sheltered from political accountability. All this has been done without passing a single law, in a manner which is remarkably free from risk of Constitutional review. It's time to expect the impossible.

%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%

%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%

The long awaited, eagerly anticipated collection of Jeff Snyder's essays, under the title, Nation of Cowards -- Essays on the Ethics of Gun Control, is being published by Accurate Press in September. Price has not yet been determined, but if you are interested in reserving a copy, you may contact the publisher at P.O. Box 190040, St. Louis, Missouri 63119, or by calling 314-352-1700.

Jeff Snyder is an attorney who works in New York City and writes a regular "Gun Rights" column for American Handgunner magazine, and can be reached by email. For those who wish to read the S&W agreement for themselves, a copy can be found at the Illinois State Rifle Association site.
----------------------------------------------
 
Back
Top