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Smith & Wesson Brands v. Estados Unidos Mexicanos

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Supreme Court of the United States
Smith & Wesson Brands v. Estados Unidos Mexicanos
Term: 2024
Important Dates
Argued: March 4, 2025
Decided: June 5, 2025
Outcome
reversed
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Clarence Thomas • Ketanji Brown Jackson

Smith & Wesson Brands v. Estados Unidos Mexicanos is a case that was decided by the Supreme Court of the United States on June 5, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on March 4, 2025.

In a 9-0 opinion, the court reversed the judgment of the United States Court of Appeals for the First Circuit, holding that because Mexico’s complaint does not plausibly allege that the defendant gun manufacturers aided and abetted the gun dealers’ unlawful sales of firearms to Mexican traffickers, the Protection of Lawful Commerce in Arms Act bars the lawsuit. Justice Elena Kagan delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned lawsuits alleging knowing violations of laws applicable to U.S. gun sales. Click here to learn more about the case's background.
  • The questions presented: "1. Whether the production and sale of firearms in the United States is the "proximate cause" of alleged injuries to the Mexican government stemming from violence committed by drug cartels in Mexico.

    2. Whether the production and sale of firearms in the United States amounts to "aiding and abetting" illegal firearms trafficking because firearms companies allegedly know that some of their products are unlawfully trafficked."[2]

  • The outcome: In a 9-0 opinion, the court reversed the judgment of the United States Court of Appeals for the First Circuit[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the First Circuit. To review the lower court's opinion, click here.


    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Smith & Wesson Brands, Inc., et al.
      • Legal counsel: Noel John Francisco (Jones Day)
    • Respondent: Estados Unidos Mexicanos
      • Legal counsel: Catherine Emily Stetson (Hogan Lovells US LLP)

    The following summary of the case was published by Oyez:[4]

    “ The Mexican government sued several U.S. gun manufacturers in federal court, alleging their practices facilitated illegal gun trafficking to Mexican drug cartels, causing harm to Mexico. The defendants moved to dismiss, arguing the lawsuit was barred by the Protection of Lawful Commerce in Arms Act (PLCAA), which prohibits certain lawsuits against gun manufacturers. The district court dismissed the case, holding that the PLCAA applied and barred Mexico's claims. Mexico appealed.


    The U.S. Court of Appeals for the First Circuit reversed, holding that while the PLCAA does apply to lawsuits by foreign governments for harm suffered abroad, Mexico’s lawsuit falls within the statute’s “predicate exception” for claims alleging knowing violations of laws applicable to gun sales. The court found Mexico adequately alleged that the defendants aided and abetted illegal gun trafficking in violation of U.S. laws, and that this proximately caused harm to Mexico. The court rejected the defendants’ arguments that the causal chain was too attenuated, finding Mexico plausibly alleged direct harm from having to combat well-armed cartels. The court remanded the case for further proceedings, allowing Mexico's lawsuit to move forward.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Whether the production and sale of firearms in the United States is the "proximate cause" of alleged injuries to the Mexican government stemming from violence committed by drug cartels in Mexico.

    2. Whether the production and sale of firearms in the United States amounts to "aiding and abetting" illegal firearms trafficking because firearms companies allegedly know that some of their products are unlawfully trafficked.[5]

    		”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 9-0 opinion, the court reversed the judgment of the United States Court of Appeals for the First Circuit, holding that because Mexico’s complaint does not plausibly allege that the defendant gun manufacturers aided and abetted the gun dealers’ unlawful sales of firearms to Mexican traffickers, the Protection of Lawful Commerce in Arms Act bars the lawsuit. Justice Elena Kagan delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    “

    All of that means PLCAA prevents Mexico’s suit from going forward. The kinds of allegations Mexico makes cannot satisfy the demands of the statute’s predicate exception. That exception permits a suit to be brought against a gun manufacturer that has aided and abetted a firearms violation (and in so doing proximately caused the plaintiff ’s harm). See §7903(5)(A)(iii); supra, at 2–3. And Mexico’s complaint, for the reasons given, does not plausibly allege such aiding and abetting. So this suit remains subject to PLCAA’s general bar: An action cannot be brought against a manufacturer if, like Mexico’s, it is founded on a thirdparty’s criminal use of the company’s product.[5]

    		”
    —Justice Elena Kagan

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, "Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos," June 5, 2025
    2. ↑ 2.0 2.1 [United States Court of Appeals for the First Circuit "U.S. Supreme Court", "23-1141 SMITH & WESSON BRANDS V. ESTADOS UNIDOS MEXICANOS" October 4, 2024]
    3. ↑ Supreme Court of the United States, "No. 23-1141," accessed November 22, 2024
    4. ↑ Oyez, "Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos," accessed November 22, 2024
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ United States Court of Appeals for the First Circuit, SMITH & WESSON BRANDS V. ESTADOS UNIDOS MEXICANOS, decided January 22, 2024
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 4, 2025
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 4, 2025
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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