Daniel Matthew Kittson v. United States

18 U.S.C. § 922(o)(1) makes it is unlawful to transfer or possess a machine gun, except “with respect to” “a transfer to or by, or possession by or under the authority of, the United States or any department or agency thereof or a State, or a department, agency, or political subdivision thereof[.]” 18 U.S.C. § 922(o)(2)(A). Under the plain text of § 922(o)(2)(A), must a transfer of a machine gun to a government agent be “under the authority of” the United States for the exemption to apply, or does the statute broadly exempt any “transfer to . . . the United States” because the “under the authority of” limitation is attached only to the separate possession clause?