A recent ruling from the New York Appellate Division in the case Salter v. Meta Platforms, Inc. may open the floodgates for lawsuits targeting gun component manufacturers – not just gunmakers themselves. In a decision that many experts call groundbreaking, the court rejected arguments from MEAN LLC, a small company that made a magazine lock used on a Bushmaster rifle involved in the 2022 Buffalo shooting. According to the Salter opinion, the court found that plaintiffs could proceed with claims of false advertising, negligence, and public nuisance.
This case is not just about a single lock. It’s about whether any gun part, even a compliance accessory, can be grounds for a lawsuit when misused – especially in a state hostile to civilian gun ownership.
From Lock to Lawsuit: What Happened in Buffalo
In May 2022, a teenage shooter carried out a racially motivated mass shooting at a grocery store in Buffalo, New York. The shooter used a Bushmaster XM-15 rifle equipped with a MEAN LLC magazine lock. The lock was designed to make the rifle compliant with New York’s SAFE Act by preventing the use of detachable high-capacity magazines. However, the shooter removed the lock – illegally modifying the firearm.
The plaintiffs – survivors and family members – claimed MEAN marketed the lock as “permanent” while also providing instructions for removing it. This, they argued, enabled the shooter to carry out the attack. The lawsuit alleged negligence, false advertising, and public endangerment under New York’s General Business Law §§ 349 and 350.
Court Says PLCAA Doesn’t Fully Shield MEAN
MEAN tried to get the case dismissed by citing the federal Protection of Lawful Commerce in Arms Act (PLCAA), which protects gun manufacturers from lawsuits over crimes committed with their products. But the New York Appellate Court didn’t agree.
The court concluded that MEAN was not shielded by PLCAA because of a critical exception known as the “predicate exception.” According to the court document, the plaintiffs had made sufficient claims that MEAN knowingly violated New York business laws – namely by falsely advertising the lock as permanent while knowingly making it removable.
This, the court ruled, could potentially meet the threshold to allow the lawsuit to proceed under PLCAA’s exceptions.
Kirk Warns: “This Case Is a Blueprint for Industry Destruction”
William Kirk, President of Washington Gun Law and a prominent 2A attorney, called this “the most dangerous lawsuit in the gun industry right now.” In a recent video, Kirk explained that this case could be used as a model by other anti-gun states to target firearm accessory manufacturers – companies that until now believed they were protected by PLCAA.
“Even though MEAN’s lock brought the rifle into compliance with New York law,” Kirk said, “the fact that the product could later be removed is now being used as a hook for a false advertising claim. That alone removes PLCAA protections. It’s absurd.”
He added that if this ruling holds, it could be used to sue anyone making gun parts – even if the shooter modifies the product against the law.
What Counts as a “Qualified Product” Under Federal Law
A key issue in the case was whether MEAN’s lock counts as a “qualified product” under the PLCAA. The court determined it did. According to the ruling, a component part that is essential to the operation or function of a firearm qualifies. Since MEAN’s magazine lock replaced the original magazine release button, the court decided it was indeed an integral component – not just an accessory.
This ruling is critical because it keeps MEAN within the scope of the law but still potentially liable under its exceptions. It also complicates the definition of what parts fall under federal protection.
Plaintiffs Say MEAN Aided and Abetted a Violation
The families of the victims also claimed that MEAN essentially aided and abetted a violation of the SAFE Act, since the company allegedly promoted how to remove its supposedly permanent lock. The court agreed that this claim was strong enough to survive a motion to dismiss.
This brings an entirely new angle to the case. If a manufacturer provides instructions for modifying a product, even legally, it may now be accused of aiding in a crime. That’s a dangerous precedent, especially for an industry already under intense scrutiny.
Court Says Consumer Protection Laws May Apply
Another part of the ruling that worries many legal experts is the court’s interpretation of New York’s General Business Law. MEAN argued that these consumer laws, Sections 349 and 350, weren’t meant to apply to firearm components. But the court disagreed.
They concluded these laws do apply to the sale and marketing of any consumer product in the state, including gun parts. The plaintiffs alleged that MEAN misled consumers by advertising the lock as non-removable, even while providing a method for removal.
This opens up another legal pathway to sue firearms industry players using general business regulations rather than specific gun control laws.
Bloomberg Law: Social Media Companies Walk Away, Gun Parts Don’t
In a related development, Meta, Google, and Reddit were dismissed from the broader Buffalo shooting case. As reported by Beth Wang at Bloomberg Law, these tech giants were protected under Section 230 of the Communications Decency Act. The court ruled that their algorithms, even if they pushed radical content, could not be treated as products.
Wang noted that dissenting judges argued social media algorithms should be considered products, potentially opening a door for future lawsuits. But in this case, the tech firms escaped liability – while MEAN LLC, a relatively small gun component manufacturer, did not.
The contrast is striking: billion-dollar platforms got immunity, but a company making a metal plug is now on trial.
Legal Experts See a Slippery Slope
The implications of this case go far beyond MEAN LLC. If courts allow lawsuits to continue simply because a product can be modified, then no gun-related manufacturer is safe – even if they followed every rule. William Kirk compared it to suing Ford because someone used one of their cars in a DUI.
“This case lets the criminal off the hook and instead shifts the blame to the toolmaker,” Kirk said. “That’s not how our legal system is supposed to work.”
Could This Case Be Used in Other States?
Yes, and that’s the biggest concern. Kirk warned that states like Washington, Oregon, Illinois, and California already have broad consumer protection laws that could be weaponized in a similar way. These laws, while supposedly about protecting consumers, could now be used to strangle firearm-related businesses through legal action.
A ruling like this gives anti-gun states a roadmap. It lets them bypass PLCAA by framing their lawsuits around business law, marketing claims, or product expectations.
A Dangerous Path Toward Blaming Tools, Not Criminals
This case shines a light on a dangerous trend—going after manufacturers and marketers of products that were legal and properly used at the time of sale. The shooter in Buffalo broke the law. He modified a rifle, deliberately, to violate the SAFE Act. Now, instead of holding the criminal solely accountable, the legal system is opening a new front: going after the people who made parts for the gun.
It’s easy to understand why victims want someone to pay. But shifting the blame from the person who committed the act to a company that followed the law sets a terrible precedent. If this spreads, the ripple effects could damage not just the gun industry – but the very idea of personal responsibility.
The Case That Could Change Everything
The Salter v. Meta ruling isn’t just another court case – it’s potentially a legal earthquake. If MEAN loses, it could mark the beginning of the end for PLCAA protections as we know them. It could mean that any part of a gun, no matter how small or lawful, could be grounds for a lawsuit if later misused.
That’s why legal observers, like William Kirk, are sounding the alarm. And it’s why everyone in the firearms community is watching this case very closely.
Mark grew up in the heart of Texas, where tornadoes and extreme weather were a part of life. His early experiences sparked a fascination with emergency preparedness and homesteading. A father of three, Mark is dedicated to teaching families how to be self-sufficient, with a focus on food storage, DIY projects, and energy independence. His writing empowers everyday people to take small steps toward greater self-reliance without feeling overwhelmed.
