Adames v. Sheahan

909 N.E.2d 742 (2009)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Adames v. Sheahan

Illinois Supreme Court
909 N.E.2d 742 (2009)

Facts

Thirteen-year-old Billy Swan found a Beretta handgun in his parents’ closet and played around with it. Based on what he saw, Billy believed that if he removed the magazine, no bullets would be left in the gun. Billy showed the gun to Josh Adames and another friend. With the magazine out, Billy jokingly pointed the gun at Adames and pulled the trigger. The gun fired, killing Adames. In juvenile court, Billy was adjudicated delinquent for the shooting and given probation. Adames’s estate (plaintiff) brought products-liability claims against Beretta U.S.A. Corporation (Beretta) (defendant) based on design-defect and failure-to-warn theories. The design-defect claim alleged that the gun lacked reasonably priced safety features that were available on other models. Most notably, the handgun (1) lacked a part that would prevent the gun from firing without the magazine and (2) used a chamber-loaded indicator, i.e., a signal that a bullet was in the chamber, that was difficult to see and understand. The failure-to-warn claim alleged that Beretta had not adequately warned users that the handgun could be fired without a magazine. The estate presented evidence that approximately 35 percent of the population did not know that some handguns could be fired with the magazines removed. According to the estate, this evidence meant that the danger was not obvious and required a specific warning. Beretta moved for summary judgment on the claims, arguing that (1) the handgun was not unreasonably dangerous or defectively designed and (2) the claims were preempted by the Protection of Lawful Commerce in Arms Act (PLCAA). The district court granted judgment to Beretta on all the claims. The appellate court affirmed the dismissal of the design-defect claims but ruled that the duty-to-warn claim could proceed. The Illinois Supreme Court agreed to review the matter.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership