State of Florida, Petitioner v. Christopher Douglas Weeks, Respondent

Summary

The Court held that the statutory definition of an antique firearm permits a reasonable construction under which the replica’s ignition or firing system is its distinctive feature. Applying the rule of lenity, it concluded that Weeks’s black-powder muzzleloader with a percussion-cap ignition system remained within the statutory exception despite the attached scope, so his conviction was reversed and sentence vacated. The Court declined to reach the constitutional vagueness issue, disapproved the contrary construction, and limited an earlier inconsistent interpretation. Justice Canady concurred on the statutory and lenity grounds, while Justice Lewis, joined by Justice Quince, would have treated the scope as disqualifying and reinstated the conviction.