We'll hear argument this morning in case 231141, Smith and Wesson Brands versus Estados Unitos Mexicanos.

Mr. Francisco.

Mr. Chief Justice, and may it please the Court, Mexico asserts that American firearms companies

are responsible for cartel violence ravaging Mexico.

Its theory is that federally licensed manufacturers

sell firearms to licensed distributors, who sell to licensed retailers, a small percentage of

whom sell to straw purchasers, some of whom transfer to smugglers, who then smuggle them

into Mexico, hand them over to cartels, who in turn use them to commit murder

and mayhem, all of which requires the government of Mexico to spend money. Needless to say,

no case in American history supports that theory, and it's squarely foreclosed by the protection

of lawful commerce in arms act.

As to proximate cause, this Court has repeatedly said there must be a direct relationship between the defendant's conduct and the plaintiff's injury.

But no such relationship exists if plaintiff's injury is caused by multiple intervening

independent crimes committed by foreign criminals on

foreign soil to inflict harm on a foreign sovereign. As to aiding and abetting, Mexico doesn't

identify a specific crime, criminal, or criminal enterprise that defendants supposedly helped.

Instead, it asserts that defendants are

liable for every illegal sale by every retailer in America because they know that a small

percentage of firearms are sold illegally and don't do more to stop it. Again, no case in history

supports that theory. Indeed, if Mexico is right,

then every law enforcement organization in America has missed the largest criminal conspiracy in

history operating right under their nose, and Budweiser is liable for every accident caused by

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