Nearly a year after ruling that the case could go forward, a federal judge has dismissed a lawsuit blaming firearm companies for a 2019 mass shooting in California.
On July 28, 2019, 19-year-old Santino William Legan opened fire at the Gilroy Garlic Festival in Gilroy, California. He killed three people and wounded 17 others before killing himself after a shootout with responding police officers.
The case, Towner v. Century Arms, was filed by more than a dozen survivors of the attack and sought to hold Century Arms partly responsible since the murderer used one of the Vermont company’s WASR-10 rifles in the shooting. The WASR-10 is legal to own in Nevada, where the shooter lived and purchased the gun, but is banned in California under state law.
Late last year, U.S. District Judge William Sessions refused to dismiss the lawsuit, claiming that the Protection of Lawful Commerce in Arms Act (PLCAA) didn’t shield Century Arms because the plaintiffs had “plausibly pled an aiding and abetting theory that satisfied the predicate exception to PLCAA’s liability bar.” However, because of the recent Supreme Court ruling in the case where Mexico sued U.S. gunmakers for drug cartel violence, Judge Sessions recently decided to dismiss the case.
According to the Supreme Court’s unanimous decision in Smith & Wesson v. Mexico, to not be covered by PLCAA, defendants must have “knowingly violated a State or Federal statute applicable to the sale or marketing” of firearms, and the violation “was a proximate cause of the harm for which relief is sought.” That prompted Judge Sessions’ dismissal.
“In late 2024, the Court issued an Opinion and Order denying Defendant Century Arms, Inc.’s motion to dismiss,” the ruling stated. “Shortly thereafter, Defendant filed a motion for reconsideration, arguing in part that a then-pending Supreme Court case may require this Court to alter its analysis. On June 5, 2025, the Supreme Court issued a unanimous opinion in that case… The parties submitted briefing following that decision. The Court has considered that briefing and the holding of the Smith & Wesson case and finds that dismissal of the claims against Century Arms is now warranted…”
As the ruling explained, the plaintiffs’ arguments fell short in many different ways.
“The issue for reconsideration, in light of Smith and Wesson, is that none of those findings are particular to the specific incident in this case,” the judge wrote. “The shooter was a Nevada resident at the time of purchase, so his purchase was presumptively legal. Plaintiffs have not alleged with any specificity that Defendants advertised or marketed their products in any way that encouraged the shooter to take his legally purchased firearm across the border to California where it would be illegally possessed.
The oversupply argument similarly fails, as applied to the shooter, because he was a Nevada resident. No matter how many surplus guns were distributed in Nevada beyond what the Nevada market could bear, the fact that the Plaintiff was a part of the Nevada market who was not engaged in some sort of broader trafficking scheme is a flaw in that reasoning.”
Ultimately, the ruling recognized the protection gunmakers are afforded under the PLCAA when violent criminals misuse their legally made and lawfully marketed products to commit heinous crimes. And it struck a blow to gun-ban groups like Brady, which had backed the lawsuit financially and had hoped it might lead to many more such claims in the future.
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