WASHINGTON, D.C. — NSSF®, The Firearm Industry Trade Association, praises the Pennsylvania Supreme Court’s unanimous decision to uphold the bipartisan Protection of Lawful Commerce in Arms Act (PLCAA), which reversed the Pennsylvania Superior Court’s decision to allow the frivolous lawsuit of Gustafson v. Springfield, Inc. The Pennsylvania Supreme Court’s decision held that the PLCAA is constitutional and applies to bar the lawsuit.
Background on Gustafson v. Springfield, Inc. and Its Importance to Gun Owners [by AmmoLand News]
What Happened:
Gustafson v. Springfield, Inc. is a case out of Pennsylvania involving the tragic accidental shooting death of 13-year-old J.R. Gustafson by a 14-year-old friend. The firearm—a Springfield Armory pistol—was legally purchased and sold through a retailer, Saloom Department Store. The shooting occurred because the juvenile mistakenly believed the gun was unloaded after removing the magazine, not realizing a round remained in the chamber.
J.R.’s parents sued the manufacturer and retailer, claiming the firearm’s design was defective and that its marketing and warnings were negligent. The lawsuit was dismissed under the Protection of Lawful Commerce in Arms Act (PLCAA)—a federal law that protects gun manufacturers and sellers from being held liable when their products are misused by third parties.
Why It Matters:
This case went all the way to the Pennsylvania Supreme Court, which ruled in favor of Springfield Armory and reaffirmed the constitutionality and strength of the PLCAA. The Court said clearly that the PLCAA bars lawsuits like this one and does not violate the Constitution’s Commerce Clause or the Tenth Amendment.
Why This Case Is Important to Gun Owners:
- Upholds Protection for Gun Makers and Sellers: The ruling affirms that manufacturers and retailers cannot be held liable when a lawfully sold, properly functioning firearm is misused by someone else—even in tragic circumstances. Without the PLCAA, anti-gun activists could use the courts to financially cripple the firearms industry.
- Defends Congressional Intent: Congress passed the PLCAA to stop a wave of lawsuits trying to hold gun companies responsible for crimes committed by unrelated third parties. The Gustafson decision reinforces that purpose and blocks attempts to chip away at this protection at the state level.
- Prevents Backdoor Gun Control: Lawsuits like this one are often part of a larger strategy to impose gun control through the courts, bypassing elected legislatures. If successful, they could lead to massive liability insurance costs and design restrictions—effectively regulating guns out of existence. This case shuts that door, at least for now.
- Solid Legal Precedent: The decision aligns with other court rulings that have upheld the PLCAA, creating stronger nationwide precedent. It also signals to state courts not to undermine the federal law under the guise of state tort or consumer protection claims.
In short, Gustafson v. Springfield, Inc. is a big win for regular American gun owners who rely on the availability and affordability of firearms. It prevents activist judges and lawyers from using lawsuits to punish lawful gun businesses for crimes and accidents they didn’t cause.
NSSF filed an amicus brief to the Pennsylvania Supreme Court supporting the defendants when this case was briefed in 2023.
The Pennsylvania Supreme Court joins the supreme courts of Missouri, Alaska, Illinois and the U.S. District Court of Appeals – the highest court in the District of Columbia – in upholding the constitutionality of the PLCAA.
To date, every state or federal appellate court to consider the constitutionality of the Protection of Lawful Commerce in Arms Act (PLCAA) has upheld the statute.
While it does not implicate the constitutionality of the PLCAA, the U.S. Supreme Court is considering a case, Estados Unidos Mexicanos v. Smith & Wesson Brands, Inc., et al., in which U.S. firearm manufacturers are petitioning the Supreme Court to reverse the U.S. Court of Appeals for the First Circuit’s decision to allow Mexico’s frivolous $10 billion lawsuit to proceed on grounds that the PLCAA prohibits such lawsuits.
“NSSF is pleased by the Pennsylvania Supreme Court’s decision holding that the PLCAA is constitutional and prevents lawsuits that attempt to blame members of the firearm industry for the criminal misuse of a lawfully sold firearm,” said Lawrence G. Keane, NSSF’s Senior Vice President and General Counsel. “While we are sympathetic to the heartbreaking loss the Gustafson family suffered, this tragic incident was the result of the criminal misuse of the firearm and the irresponsible negligence of the owner of the firearm who failed to safely secure it to prevent unauthorized access by an unsupervised juvenile. The Pennsylvania Supreme Court’s unanimous decision shows, once again, that the PLCAA is solidly rooted in foundational tort law.”
Justice Sallie Updyke Mundy, writing for a unanimous court, held that the plain language of the PLCAA prohibits the plaintiffs’ claims in this case.
One justice did not participate in the consideration or decision. The court agreed that alleged harm to the Gustafson family resulted from the juveniles’ “criminal or unlawful misuse” of a firearm. It also found that the juvenile intentionally discharged the firearm, negating claims of product liability exceptions under the PLCAA. The court further held that the PLCAA does not violate the Commerce Clause, the Tenth Amendment or principles of federalism.
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About The National Shooting Sports Foundation
NSSF is the trade association for the firearm industry. Its mission is to promote, protect and preserve hunting and shooting sports. Formed in 1961, NSSF has a membership of thousands of manufacturers, distributors, firearm retailers, shooting ranges, sportsmen’s organizations, and publishers nationwide. For more information, visit nssf.org
