The Protection of Lawful Commerce in Arms Act (PLCAA) is a U.S law, passed in 2005, that protects firearms manufacturers and dealers from being held liable when crimes have been committed with their products. Both arms manufacturers and dealers can still be held liable for damages resulting from defective products, breach of contract, criminal misconduct, and other actions for which they are directly responsible. They may also be held liable for negligent entrustment when they have reason to know a gun is intended for use in a crime. The PLCAA is codified at 15 U.S.C. §§ 7901–7903. Background In the years before passage of the act, victims of firearms violence in the United States had successfully sued manufacturers and dealers for negligence on the grounds that they should have foreseen that their products would be diverted to criminal use. In 1998, Chicago Mayor Richard M. Daley sued gun makers and dealers, saying: "You can't expect the status quo on businesses which make money and then have no responsibility to us as citizens." The city of Bridgeport, Connecticut, also sued several gun companies. Mayor Joseph Ganim said that the city's action aimed at "creating law with litigation.... That's the route that we're going because [the industry has] always very effectively, with big money, lobbied the legislature and kept laws from being passed." In 2000, Smith & Wesson, facing several state and federal lawsuits, signed an agreement brokered by President Bill Clinton, in which the company voluntarily agreed to implementing various measures in order to settle the suits. The agreement required Smith & Wesson to sell guns only through dealers that complied with the restrictions on all guns sold regardless of manufacturer, thus potentially having a much wider potential impact than just Smith & Wesson. HUD Secretary Andrew Cuomo was quoted as saying that gun manufacturers that did not comply would suffer "death by a thousand cuts", and Eliot Spitzer said that those who didn't cooperate would have bankruptcy lawyers "knocking at your door". In January 2005, New York City passed a law allowing lawsuits against gun manufacturers and dealers that did not voluntarily implement certain gun control measures. As of 2020, at least six courts at the federal, state and appellate levels had upheld the law’s constitutionality, although an appeals court in Pennsylvania found it in violation in 2020. Remington Arms paid a $73 million settled with Sandy Hook plaintiffs in