Pennsylvania Supreme Court Unanimously Affirms PLCAA's Constitutionality

In a significant legal decision on March 31, the Pennsylvania Supreme Court ruled unanimously that the Protection of Lawful Commerce in Arms Act (PLCAA) is constitutional and effectively bars the lawsuit in Gustafson v. Springfield, Inc.

The case stemmed from a tragic 2016 incident in Mt. Pleasant, Pennsylvania, where a 13-year-old was fatally shot by a 14-year-old friend. Following the incident, the 14-year-old admitted to his actions and was subsequently adjudicated delinquent on involuntary manslaughter charges in juvenile court.

The parents of the deceased filed litigation against Springfield Armory, the manufacturer of the firearm, and the retailer that sold it. Their complaint included allegations of defective design, negligent design and sale, and inadequate warnings and marketing practices.

Initially, the trial court dismissed the complaint with prejudice, citing protections under the PLCAA. After plaintiffs appealed, the Superior Court reversed this decision and remanded the case. However, the Pennsylvania Supreme Court's recent ruling overturned the Superior Court's decision, determining that the defendants were indeed shielded from liability under federal law.

The court stated: "Plaintiffs' action is a qualified civil liability action pursuant to the PLCAA and does not qualify under the Act's product liability exception. As such, the PLCAA operates to bar Plaintiffs' action. Further, the PLCAA is a valid exercise of Congress's Commerce Clause authority and does not violate the Tenth Amendment or principles of federalism."

This decision aligns Pennsylvania with other jurisdictions that have upheld the PLCAA's constitutionality, including the supreme courts of Missouri, Alaska, Illinois, and the U.S. District Court of Appeals for the District of Columbia. To date, every state and federal appellate court that has examined the constitutionality of the PLCAA has affirmed the statute.

The National Shooting Sports Foundation's (NSSF) senior vice president and general counsel, Lawrence Keane, expressed support for the ruling.

"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," Keane remarked in a news release. "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."