District of Columbia v. Beretta U.S.A. Corp.

940 A.2d 163 (2008)

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District of Columbia v. Beretta U.S.A. Corp.

District of Columbia Court of Appeals
940 A.2d 163 (2008)

Facts

Several individuals and the District of Columbia (district) (plaintiffs) sued multiple firearms manufacturers and dealers (defendants) for violating a district law. Under the district’s law, any firearms manufacturers or dealers who made or sold assault weapons or machine guns were strictly liable for any tort injuries caused by assault weapons or machine guns in the District of Columbia. Thus, regardless of whether a manufacturer or dealer had breached any duty of care or reasonableness, the entity had a duty to compensate a shooting victim for injuries caused by these types of weapons in that geographic area. While the lawsuit was pending, Congress enacted the Protection of Lawful Commerce in Arms Act (PLCAA). The PLCAA’s stated purpose was to reduce the burden on interstate commerce caused by lawsuits against the firearms industry for injuries committed by criminals. The PLCAA achieved this purpose by preempting most civil claims against federally licensed firearms dealers and manufacturers if the claims were based on injuries caused by the criminal use of a firearms product. However, not all claims were preempted. The PLCAA had what was referred to as the predicate exception. The predicate exception allowed a claim if (1) the claim was based on the defendant’s violation of a predicate, i.e., underlying, statute that applied to firearms sales or marketing and (2) the predicate violation was a proximate cause of the claimed injury. The trial court found that the PLCAA preempted the claims based on the district’s strict-liability law and dismissed the lawsuit. The individuals and the district appealed, arguing that their claims should be allowed because the defendants’ alleged violation of the strict-liability law fell within the predicate exception.

Rule of Law

Issue

Holding and Reasoning (Farrell, J.)

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