VICTORY FOR FIREARM MANUFACTURER IN MASS SHOOTING CASE
May 29, 2026 – RLF secured a complete dismissal of a wrongful death and negligence case in Florida state court on behalf of one of its firearm industry clients, a firearm manufacturer, when the Court granted a motion to dismiss based on the immunity provided to members of the firearm industry by Florida Statutes Section 790.331 (“Florida Immunity Statute”).
The case involved a fatal, racially motivated mass shooting in Jacksonville, Florida, on August 26, 2023, during which the shooter murdered three people at a Dollar General store using an AR-15 platform rifle. Plaintiffs were the estate of one of the individuals murdered by the shooter and two individuals injured by the shooter. Plaintiffs sued the rifle manufacturer and the firearms dealer who transferred the rifle to the shooter, asserting 18 claims for negligent marketing, sale and entrustment.
In support of the manufacturer’s motion to dismiss, RLF argued that Plaintiffs’ claims were barred by the Florida Immunity Statute, the federal Protection of Lawful Commerce in Arms Act (“PLCAA”), and failed under Florida common law. The Court found that, pursuant to the Florida Immunity Statute, “the Legislature has decreed that the unlawful use of a firearm is the sole proximate cause of any resultant injuries, not the antecedent sale of that firearm,” and that the Florida Immunity Statute “has done away with all negligence-based tort claims against gunmakers and sellers for any injuries caused by the unlawful use of a firearm.” Concluding that the Florida Immunity Statute “provides a clear legal basis for complete dismissal,” the Court declined to address the immunity provided by the PLCAA and dismissed all claims with prejudice.
RLF is pleased to have obtained victory at the very early stages in this litigation. Renzulli Law Firm, LLP vigorously defends its firearm industry clients nationwide, regularly obtaining successful results.