Jody Hendrick v. Academy I, LP, D/B/A Academy Sports + Outdoors

CourtMissouri Court of Appeals
DecidedOctober 29, 2024
DocketWD86911
StatusPublished

This text of Jody Hendrick v. Academy I, LP, D/B/A Academy Sports + Outdoors (Jody Hendrick v. Academy I, LP, D/B/A Academy Sports + Outdoors) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jody Hendrick v. Academy I, LP, D/B/A Academy Sports + Outdoors, (Mo. Ct. App. 2024).

Opinion

Missouri Court of Appeals Western District

JODY HENDRICK, ET AL., ) ) WD86911 Appellants, ) v. ) OPINION FILED: ) ACADEMY I, LP, D/B/A ACADEMY ) October 29, 2024 SPORTS + OUTDOORS, ET AL., ) ) Respondents. ) )

Appeal from the Circuit Court of Jackson County, Missouri The Honorable James F. Kanatzar, Judge

Before Division Three: Mark D. Pfeiffer, Presiding Judge, Thomas N. Chapman, Judge, and Janet Sutton, Judge

Jody and Jessica Hendrick (“Hendrick”) 1 appeal the Jackson County Circuit

Court’s dismissal of their action for negligence and loss of consortium against Academy

I, LP d/b/a Academy Sports + Outdoors (“Academy Sports”), and Christopher Gaither

(“Gaither” and collectively “Defendants”) based on the federal Protection of Lawful

1 This opinion will refer to the Hendricks in the singular form because the claim of Judy Hendrick for loss of consortium is derivative of Jody Hendrick’s negligence claim. “A claim for loss of consortium is derivative only; for one spouse to recover for loss of consortium, the other spouse must have a valid claim for personal injury.” Price v. Thompson, 616 S.W.3d 301, 314 (Mo. App. W.D. 2020) (internal quotes and citation omitted). Commerce in Arms Act, 15 U.S. C. section 7901, et seq. (“PLCAA” or “Act”). Hendrick

alleged that Defendants were negligent in failing to implement safeguards at an Academy

Sports store concerning a firearm and ammunition, which were stolen at knifepoint and

then used to shoot him several times. Hendrick raises two points on appeal. In his first

point, he contends that the trial court erred in granting Defendants’ motion to dismiss

because his claim did not constitute a “qualified civil liability action” as defined by the

PLCAA in that there was not a “sale” of a firearm. In point two, Hendrick argues that the

trial court erred in denying his alternative request to amend the petition pursuant to Rule

67.06 to allege a recognized exception in the PLCAA, negligent entrustment. The

judgment is affirmed.

Factual and Procedural Background 2

Academy Sports is a retail seller of firearms and ammunition lawfully doing

business in Missouri, and at all relevant times, Gaither was an employee of Academy

Sports. On January 2, 2020, an individual entered the Academy Sports store in Liberty,

approached the gun counter, contacted Gaither, and said he was interested in seeing a

handgun. Gaither retrieved the requested handgun from a locked safe and handed control

of it to the individual to look over, handle, and inspect. The handgun was not equipped

with any trigger locking mechanism, and Gaither did not perform any background or ID

check before providing it to the individual. The individual informed Gaither that he

2 The facts set forth below, taken from Hendrick’s petition, are treated as true and are liberally construed in favor of the plaintiffs. Lynch v. Lynch, 260 S.W.3d 834, 836 (Mo. banc 2008).

2 wanted to purchase the handgun, and Gaither asked him for his driver’s license, which he

provided. At some point during the exchange, the individual placed a box of ammunition

he had obtained from a nearby shelf onto the counter within his reach. Gaither also

allowed the handgun to remain on the counter within the individual’s reach while he ran a

required background check. The background check came back “Denied.” The individual

then opened his coat, pulled out a knife, jumped over the counter, and grabbed the

handgun and ammunition. Upon seeing the knife, Gaither ran out from behind the

counter.

The individual exited the store with the handgun and ammunition, ran to his

vehicle, and drove directly to Landmark Dodge in Independence. He entered the used car

area, approached Hendrick, and shot him several times at point blank range with the

handgun and ammunition obtained from Academy Sports. The individual started to

leave, paused at the doorway, and reentered the business and shot Hendrick again at point

blank range. Hendrick was rushed to the hospital with gunshot wounds to his head, torso,

and leg.

On February 9, 2023, Hendrick filed his petition against Defendants for

negligence. He alleged that Defendants were negligent in the following ways:

Failure to properly inspect and maintain the area in question to discover the dangerous condition thereof (the accessibility of both the firearm and the ammunition);

Failure to conduct a firearm background check prior to allowing a customer to handle and/or inspect a firearm for purchase;

3 Failure to place the unpurchased firearm back into a locked drawer, safe, or display case while conducting a firearm background check;

Failure to remove the magazine from the firearm when relinquishing control of the firearm;

Failure to place and/or keep a security lock function on firearms until after a customer has purchased the firearm; and

Failure to correct the aforementioned dangerous conditions.

Hendrick also alleged that Gaither was negligent for failure to ensure the firearm was not

accessible to the customer and that Academy Sports was negligent for failure to store

ammunition in a locked cabinet; for failure to store firearms and ammunition in different

locked areas of the store; for failure to implement safeguards including but not limited to

proper security measures such as alarm sounds, locks, and/or proper staffing; and for

failure to properly train staff regarding the dangers of allowing customers access to

ammunition and firearms before completing a proper background check.

Hendrick further alleged that, as a result of Defendants’ actions or inactions, he

suffered severe personal injuries to his face, head, neck, and upper body, experienced

severe physical and mental anguish, incurred medical expenses, and will likely continue

to incur expenses in the future. Judy Hendrick alleged that, as a result of Hendrick’s

injuries, she suffered and will continue to suffer the loss of consortium of her husband.

On July 10, 2023, Defendants filed a motion to dismiss Hendrick’s petition

pursuant to the PLCAA and for failure to state a claim upon which relief can be granted

under Rule 55.27(a)(6). They asserted that Hendrick’s claim was barred by the PLCAA,

4 a federal immunity statute that prohibits a civil action from being filed against a seller of

a firearm or ammunition for damages resulting from the criminal or unlawful use of the

firearm or ammunition by a third party. Specifically, they argued that Hendrick’s

negligence claim was a qualified civil liability action prohibited by the PLCAA and was

not one of the six narrow exceptions under the Act.

In his suggestions in opposition to Defendants’ motion to dismiss, Hendrick

argued that the PLCAA did not apply to the facts of the case because the Act involves

“commerce” or the “sale” of firearms. He asserted that his case involved Defendants’

negligent storage and access to firearms and ammunition at the Liberty store, not the

legal sale of a firearm and a third-party bad actor. In the alternative, Hendrick requested

an opportunity to amend his petition under Rule 67.06 “to correct any pleading

deficiencies” the court might find.

On January 22, 2024, the trial court entered its judgment and order of dismissal

granting Defendants’ motion to dismiss pursuant to the PLCAA. It found that the Act

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Related

Estate of Kim Ex Rel. Alexander v. Coxe
295 P.3d 380 (Alaska Supreme Court, 2013)
Doran v. Chand
284 S.W.3d 659 (Missouri Court of Appeals, 2009)
Lynch v. Lynch
260 S.W.3d 834 (Supreme Court of Missouri, 2008)

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