Both the Marlin and the Winchester (Rossi, Puma) 1894 uses a loading lifter for the cartridge. The Puma is actually just a copy of the Winchester 1892. The nose of the cartridge relies on gravity to keep it in place. On the Winchester 1892s and 1894s, the bullet can tip completely out of the top of the action, and not feed at all. On the Marlin 1894, the closed top of the receiver will prevent this, but the nose could be pushed into the area above the chamber, effectively stopping feeding. The only lever action rifles virtually jam-free upside down will be the Henry (1860), Winchester 1866, Winchester 1873, and Winchester 1876 rifles. These use a carrier block to raise the cartridge to chamber level and the bolt merely pushes it directly into the chamber. The opening in the top of the carrier is not large enough to let the cartridge pass through. However, these are weaker actions, and are not made in very powerful calibers, such as .44 Magnum.