“Despite (the buyer’s) stated aspiration to open a gun shop in Buffalo, the record is devoid of evidence supporting plaintiffs’ theory that, merely by selling handguns to (the buyer) Brown intended to serve the New York market,” the court ruled.
Brown, in this case, was not part of a scheme to traffic guns into New York, the court held. The judges said there was no way for him to know what would happen to the firearms after they were sold so he did not purposefully enter into the New York market at the time.
The buyer later pleaded guilty to federal gun trafficking charges.
Brown's attorney said that "the case's main significance was that this was the lawful sale of a lawful product."
The complete decision can be found here.