Kurt Stokinger et al. v. Armslist, LLC

2024 DNH 056
CourtDistrict Court, D. New Hampshire
DecidedJuly 15, 2024
Docket23-cv-428-PB-TSM
StatusPublished
Cited by1 cases

This text of 2024 DNH 056 (Kurt Stokinger et al. v. Armslist, LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Kurt Stokinger et al. v. Armslist, LLC, 2024 DNH 056 (D.N.H. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Kurt Stokinger et al.

v. Case No. 23-cv-428-PB-TSM Opinion No. 2024 DNH 056 Armslist, LLC

MEMORANDUM AND ORDER

Kurt Stokinger, a former Boston police officer, was shot in the line of

duty by a felon in possession of a handgun that was at one point sold via

Armslist.com, a website that hosts firearms classifieds. Stokinger and his

spouse sued Armslist for negligence and other torts, alleging that Armslist’s

failure to institute certain safeguards on its website enabled the shooter to

unlawfully obtain the handgun. Armslist has moved to dismiss the complaint

pursuant to Federal Rule of Civil Procedure 12(b)(2), arguing that this court

lacks personal jurisdiction to hear the claims. I agree and therefore grant the

motion to dismiss. 1

1 Armslist filed a concurrent motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. Doc. 20. That motion is denied as moot in light of my conclusion that I lack jurisdiction to hear the plaintiffs’ claims. I. BACKGROUND

A. Facts

1. Armslist’s Website and Business Model

Armslist is a limited liability company organized and headquartered in

Pennsylvania. Doc. 21-2 at 2. Armslist owns and operates Armslist.com,

which is a “craigslist-style, for-profit, online firearms marketplace that

enables users to sell firearms and firearm-related accessories to private

individuals through website postings.” Doc. 21-9 at 4.

The website enables users to create listings offering to either buy or sell

various products. Doc. 21-2 at 5. When creating a listing, users are prompted

to input certain information, including their location, email address, and a

description of the item for sale. Id. at 4-5. To locate listings of interest, users

can input a keyword into a search bar and then filter the results by various

criteria, including location. Id. at 3. This filtering function allows users to

limit their results to items listed for sale in a particular state, including New

Hampshire. Id. Users can then respond to listings by either utilizing an email

link embedded in the listing or contacting the seller directly using

information provided in the listing. Id. at 5-6. All transactions occur offline,

without any further involvement from Armslist. Id.

Generally speaking, Armslist’s users fall into one of two categories.

“Private parties” are individual users who wish to make an occasional sale or

2 purchase. Id. at 4. Private parties are not required to register an account

with Armslist and can make a limited number of postings, free of charge. Id.

at 4, 6. “Premium vendors,” in contrast, are typically federally-licensed

firearms dealers seeking to engage in more regular sales. Id. at 3. Premium

vendors must register an account and are subject to Armslist’s approval. Id.

To obtain approval, a vendor must provide evidence of its federal firearms

license or else commit to selling only non-firearm products, such as gun

holsters or other accessories. Id. Premium vendors pay recurring membership

fees and, in exchange, are permitted to create an unlimited number of

listings. Id.

Armslist derives revenue from the membership fees of its premium

vendors and fees charged to third-party advertisers who purchase advertising

space on the website. Id. at 6. Armslist does not obtain any revenue directly

from private parties or their listings. Id.

2. Underlying Facts

In 2015, Derek McNamara posted a Glock Model 27 handgun for

private sale on Armslist. Doc. 34-1 at 12. Sara Johnson, a resident of New

Hampshire, responded to McNamara’s listing with an offer to purchase the

handgun. Id. McNamara agreed and, after confirming that Johnson had the

required permits, he transferred the firearm to her in Warner, New

Hampshire. Id. at 12-13.

3 Unbeknownst to McNamara, Johnson was a gun trafficker who had

used Armslist to purchase dozens of firearms, often acting as a straw

purchaser for her then-boyfriend, Daniel Sullivan. Id. at 5; Doc. 1 at 29.

Plaintiffs allege that Johnson later sold McNamara’s firearm to Grant

Headley, a prohibited person with several felony convictions, either directly

or indirectly through Sullivan. Doc. 1 at 29-30.

On January 8, 2016, Headley used the handgun that he allegedly

obtained from Johnson to shoot Stokinger multiple times in the leg while

Stokinger was working as a police officer in Boston, Massachusetts. Id. at 3-4.

Stokinger suffered permanent injuries as a result, prematurely ending his

career as a police officer. Id. at 42-43.

B. Procedural History

In October 2018, Stokinger and his wife brought suit against Armslist

in Massachusetts state court for negligence and other torts. Doc. 21-5 at 28-

38. Armslist responded with two separate motions to dismiss. The first

asserted that the court lacked personal jurisdiction and the second argued

that the plaintiffs’ claims failed on the merits because they were preempted

by Section 230 of the Communications Decency Act, 47 U.S.C. § 230. Doc. 21-

10 at 5.

The Massachusetts Superior Court granted Armslist’s second motion to

dismiss on the merits, but declined to address Armslist’s personal jurisdiction

4 argument. Doc. 21-6 at 2 n.3. Armslist filed a motion for partial

reconsideration, asking the court to address its personal jurisdiction motion

in order to preclude a potential remand on that basis should the plaintiffs

appeal. Doc. 21-9 at 3. The court issued a brief order concluding that it lacked

personal jurisdiction based on the present record but that the plaintiffs were

granted leave to obtain jurisdictional discovery. Id.

Although most of the plaintiffs’ discovery was aimed at Armslist’s

contacts with Massachusetts, several requests also sought information

related to Armslist’s contacts with New Hampshire. For example, the

plaintiffs requested documents pertaining to Armslist’s communications with

New Hampshire-based users and third-party advertisers, as well as

Armslist’s marketing efforts in the state. Doc. 21-7 at 5-14. After initially

objecting to the requests, Armslist agreed to provide the plaintiffs with

limited discovery on its contacts with New Hampshire. Doc. 21-8 at 3-4.

Armslist responded to the plaintiffs’ document requests, but only as to its

contacts with New Hampshire in 2015 and 2016, which Armslist viewed as

the relevant time period for determining personal jurisdiction. Id.

Armslist represented that it had 8 New Hampshire-based premium

vendors in 2015 and 11 in 2016, which resulted in $1,670 in revenue in 2015

and $2,910 in 2016. Doc. 21-2 at 7. Armslist provided the plaintiffs with all

documents regarding its communication with and solicitation of New

5 Hampshire-based premium vendors during this time frame, which consisted

of a single email from a New Hampshire firearms dealer providing Armslist

with a copy of the dealer’s federal firearm license. Doc. 21-8 at 3, 6-7.

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Stokinger v. Armslist, LLC
D. New Hampshire, 2024

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