Peterson posits that suppressors are “an integral part of a firearm”
and therefore warrant Second Amendment protection: “Inasmuch as a bullet
must pass through an attached [suppressor] to arrive at its intended target,”
suppressors are used for casting and striking and thus fit Heller’s definition.
But that is wrong. A suppressor, by itself, is not a weapon. Without being
attached to a firearm, it would not be of much use for self-defense. And
unless a suppressor itself is thrown (which, of course, is not how firearms
work), it cannot do any casting or striking.3
See United States v. Hasson, No.
GJH-19-96, 2019 WL 4573424, at *4 n.5 (D. Md. Sept. 20, 2019) (noting that
a suppressor “could be thrown at someone like a shoe or a baseball, which,
most would agree, are not arms protected by the Second Amendment”).
While a suppressor might prove useful to one casting or striking at another,
that usefulness does not transform a gas dissipater into a bullet caster.
Instead, we agree with the Tenth Circuit that a suppressor “is a firearm
accessory . . . not a weapon.” Cox, 906 F.3d at 1186.4 And while possession
of firearms themselves is covered by the plain text of the Second
Amendment, possession of firearm accessories is not.