sbhaven has cited the key provisions of the CT statutes that were considered in developing this product, but to summarize, once the firearm no longer meets all three requirements â€“ (1) semi-automatic, (2) centerfire, and (3) the ability to accept a detachable magazine â€“ it basically avoids classification as an assault weapon. There are, actually, a couple of other hurdles that must also be passed: the fixed magazine cannot be larger than 10 round capacity (by design or by pinning); the overall length must be 30 inches or more; it cannot be a copy or a duplicate of a named banned weapon; etc. (For the latter provision, the State Police have published three criteria that must be considered. This design passes that test too.)
My original approach to addressing the CT statutes was a special lower receiver designed from the beginning with those statutes in mind. It arguably goes well beyond the minimum requirements to comply. It is still listed on my website as a Model CGAR15FM lower receiver and is available for purchase through an FFL gun dealer. It actually requires removal of the bolt catch and insertion of the magazine from the top of the lower receiver during installation. Both it and the MRK-1 kit require that the magazine is empty when loaded into the magazine well. I have shown that variant to three prominent attorneys in CT, all deeply involved in advising their clients on CTâ€™s gun laws, and have received an endorsement from all three. (You can see their names and contact information on the www.ctlegalars.com
website.) I have also demonstrated that design to the CT State Police officers in charge of the Special Licensing and Firearms office in Middletown. IAW policy set by the current administration, the State Police will not issue a formal opinion letter and they are careful not to give even verbal approval, but the officers I spoke to candidly did not identify any technical violations of the law. Itâ€™s a very elegant and effective design, but the downsides are that when produced in small lots it is quite expensive and it will not easily revert to a â€œnormalâ€ AR-15 configuration if the law ever changes (or no longer matters).
This MRK-1 product is based on the same method of securing the magazine in the lower receiver and, as such, requires disassembly of the firearm action. It meets the standard of not being â€œcapable of accepting a detachable magazine.â€ Iâ€™ve gone back to one of the three attorneys mentioned above for a re-look and the original opinion stands. Iâ€™ve also, again as a courtesy, shared information about the design (and my intent to sell the product) with the State Police. The key differences in this approach, as compared to the CGAR15FM receiver, are that (1) it works with any standard AR-15 lower receiver made from a forging (rather than a billet), (2) the conversion is reversible so you can reacquire full functionality in a matter of minutes if needed, and (3) it costs a small fraction of the CGAR15FM receiver. (The concept could be made to work with a billet receiver, but it might need some minor dimension changes in the retention fitting to deal with different receiver wall thickness measurements in the billet version.) There is no guarantee that the AW status of an AR equipped with this MRK-1 device wonâ€™t be challenged by some law enforcement officer, but IMHO this design is less likely to be challenged than a mechanism that only requires you to pull the rear takedown pin to swap full magazines.