Estate of Simone Young Kim, by Its Personal Representative, Serena Alexander, Chu Cha Kim, and Ambrosus H. Kim…

Summary

The court held that the Protection of Lawful Commerce in Arms Act bars general negligence actions against firearm sellers arising from third-party criminal misuse unless a statutory exception applies, and that the Act is constitutional. It further held that a firearm theft cannot, by itself, support claims under the Act's knowing-violation, negligence-per-se, or negligent-entrustment exceptions. The court vacated the summary judgment ruling and remanded because the superior court may have improperly excluded or failed to fully consider expert-affidavit evidence bearing on whether the rifle was stolen or knowingly transferred. No separate opinions were provided.