Justia Products Liability Opinion Summaries

A woman developed mesothelioma and lung cancer, allegedly due to exposure to asbestos dust brought home on her husband’s work clothing. Her husband, a professional insulator, installed asbestos-containing insulation on turbines manufactured by a defendant company at a Maryland power plant in the 1960s. Facilities for workers to shower or change at the worksite were not provided, so he regularly brought dusty work clothes home. The woman, who never visited the worksite, handled and laundered these clothes, potentially exposing herself to asbestos fibers. After her death, her estate continued the personal injury and wrongful death action against the manufacturer and others.The Superior Court of the District of Columbia initially granted summary judgment to the defendant on all claims, including strict liability for design defect. On appeal, the District of Columbia Court of Appeals vacated the summary judgment concerning the design defect claim and remanded the case. Following further proceedings, the Superior Court again granted summary judgment in favor of the defendant, finding that as a bystander, the plaintiff could not recover on a strict liability theory. This led to a second appeal, after which the District of Columbia Court of Appeals certified to the Supreme Court of Maryland the question of whether, under Maryland law, a household member exposed to asbestos dust brought home by a worker must prove an additional element of duty in a strict liability design defect claim.The Supreme Court of Maryland held that a household member in the plaintiff’s position is not required to prove the additional element of duty beyond the four elements of strict liability for design defect as set forth in Phipps v. General Motors Corp. The court clarified that, unlike failure to warn and negligence claims, duty is not a required element for strict liability design defect claims, whether for users, consumers, or household members exposed through no fault of their own. View "Quinn v. General Electric Co." on Justia Law

A workplace accident in 2020 resulted in the death of Colby Eldon Johnson, who was using a self-unloading bed manufactured by SRM-Double L, LLC (“SRM”) on his employer’s truck. Colby’s father, Harry Johnson, filed suit against SRM and others, alleging products liability and negligence. During pretrial proceedings, Johnson failed to submit timely responses to SRM’s discovery requests and did not file his opposition to SRM’s summary judgment motion by the court-ordered deadline. He later filed late motions and exhibits, citing scheduling conflicts and unresolved discovery issues.The District Court of the Fifth Judicial District, Gooding County, granted SRM’s motions to strike Johnson’s untimely filings, finding no valid justification for the delay. Consequently, the court treated SRM’s summary judgment motion as unopposed and granted summary judgment in SRM’s favor, finding Johnson’s claims barred by Idaho statutes. The court also awarded attorney fees and sanctions against Johnson and his counsel under Idaho Rules of Civil Procedure 11 and 37, based on alleged misrepresentations and discovery delays.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision to strike Johnson’s untimely filings, finding no abuse of discretion. However, the Supreme Court reversed the grant of summary judgment, holding that the lower court failed to analyze whether SRM had met its burden under Rule 56(a), which is required even if the motion is unopposed. The Supreme Court affirmed the award of attorney fees under Rule 37 for discovery violations but reversed the sanctions under Rule 11 because the only support for the sanctions was inadmissible hearsay. The case was remanded for further proceedings on the merits. Attorney fees on appeal were denied, as no party had yet prevailed. View "Johnson v. SRM-Double L, LLC" on Justia Law

A police sergeant was injured during a training exercise when his department-issued semi-automatic pistol discharged while holstered, resulting in a gunshot wound to his leg. He could not explain what caused the trigger to be actuated but maintained that his hand was not on the weapon at the moment it discharged. He and his wife sued the firearm manufacturer, alleging strict products liability and negligence, and asserting that the pistol’s design was defective—particularly, that it lacked an external safety mechanism, making it more susceptible to unintentional discharge.The case was first heard in the United States District Court for the Northern District of New York. The plaintiffs sought to introduce expert testimony to establish that the design defect, specifically the lack of an external safety, caused the injury. The district court excluded the experts’ causation opinions, finding them unreliable because the experts did not adequately address the specifics of the incident or test their theories under similar circumstances. The court then granted summary judgment for the manufacturer, holding that under New York law, expert testimony as to proximate causation was necessary due to the complexity of the issues.The United States Court of Appeals for the Second Circuit reviewed the case. It affirmed the district court’s decision to exclude the experts’ causation opinions, finding the exclusion within the court’s discretion. However, the appellate court held that New York law does not require expert testimony on proximate causation in all product liability cases, especially where jurors can use their own judgment, aided by other evidence, to assess causation. The court concluded that a reasonable jury could decide, based on the design-defect evidence and the circumstances of the accident, whether an external safety would have prevented the injury. The Second Circuit therefore vacated the district court’s grant of summary judgment and remanded the case for further proceedings. View "Hayes v Board of Education of the City of Chicago" on Justia Law

A police sergeant was injured during a training exercise when his department-issued firearm, a Sig Sauer P320 pistol, discharged while holstered. The officer did not know what had caused the trigger to move but testified that his hand was not on the weapon at the time. Emergency reports provided a slightly different account, suggesting the pistol discharged while being holstered. The officer and his wife sued the manufacturer, alleging the pistol was defectively designed, in particular because it lacked an external safety, and argued that this defect led to the injury.The case was first reviewed by the United States District Court for the Northern District of New York. The plaintiffs offered expert testimony to support their claims about the pistol’s defective design and to establish that the absence of an external safety was the cause of the injury. The district court accepted the experts’ opinions regarding the alleged design defect but excluded their causation opinions, finding them insufficiently tied to the facts of the accident. The court reasoned that the experts could not reliably explain how the accident happened or how an external safety would have prevented it. The district court then granted summary judgment for the defendant, concluding that under New York law, expert testimony was required to establish proximate causation in this case.The United States Court of Appeals for the Second Circuit reviewed the case. It determined that the district court did not abuse its discretion by excluding the causation opinions of the experts. However, the appellate court held that New York law does not always require expert testimony on proximate causation if a jury can use its own judgment along with the evidence presented. The court found that the jury could rely on the accepted design-defect opinions, the witness’s account, and its own evaluation of the firearm and holster. The court vacated the district court’s judgment and remanded the case for further proceedings. View "SLT Imports Inc v. SAR Transport Systems Pvt Ltd" on Justia Law

A police sergeant was injured when his department-issued pistol accidentally discharged during a training exercise. He did not know what caused the trigger to actuate but testified that the pistol fired while holstered and his hand was not on the weapon. The injured officer and his spouse sued the firearm manufacturer, alleging that the pistol was defectively designed because it lacked an external safety, and claimed that this defect caused the injury. They sought to support their claims with expert testimony asserting that the pistol’s design was unreasonably dangerous due to its lack of external safety features and that an external safety would have prevented the incident.The United States District Court for the Northern District of New York excluded the causation opinions of the plaintiffs’ experts, finding that these experts could not reliably explain how the accident happened or how an external safety would have prevented it. The district court then granted summary judgment to the manufacturer, holding that, under New York law, expert testimony was required to establish proximate causation because the issue was too complex for a jury.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the district court did not abuse its discretion in excluding the experts’ causation opinions, as they were insufficiently linked to the specifics of the accident. However, the appellate court determined that the district court erred in granting summary judgment. The Second Circuit clarified that New York law does not require expert testimony to establish proximate causation in all product liability cases; jurors may use their common sense and the available evidence, including unchallenged expert opinions about the product’s design, to decide if the alleged defect caused the injury. The appellate court also rejected the manufacturer’s argument based on New York’s optional equipment doctrine. The judgment was vacated and the case remanded for further proceedings. View "The Satanic Temple, Inc. v. Newsweek Digital LLC" on Justia Law

A police sergeant suffered a gunshot injury to his leg when his department-issued Sig Sauer P320 pistol discharged while he was conducting a training exercise. He did not know what caused the trigger to move, but testified that the pistol was holstered and his hand was not on the gun at the time. Emergency responders’ documentation, however, suggested the gun discharged while he was still holstering it. The injured officer and his spouse brought strict products liability and negligence claims against the manufacturer, alleging that the P320 was defectively designed because it lacked an external safety, making it prone to accidental discharges.The United States District Court for the Northern District of New York excluded the causation opinions of the plaintiffs’ experts, finding their analysis unreliable because they did not explain how the accident happened or how an external safety would have prevented it. The district court then granted summary judgment for the manufacturer, concluding New York law required expert testimony to establish proximate causation in a case involving the operation of a complex product like a firearm, and the plaintiffs could not meet that burden without admissible expert causation opinions.The United States Court of Appeals for the Second Circuit reviewed the case and held that the district court did not abuse its discretion by excluding the experts’ causation opinions, as they were not sufficiently grounded in the facts of the accident. However, the Second Circuit ruled that the district court erred in granting summary judgment. The appellate court held that, under New York law, expert testimony on causation is not always required if a jury can determine causation based on its own judgment, the characteristics of the product, and the evidence presented. The court vacated the district court’s judgment and remanded the case for further proceedings. View "Colwell v. Sig Sauer, Inc." on Justia Law

A plaintiff alleged that she suffered serious eye injuries, including blindness in one eye, after receiving an injection of a pharmaceutical product manufactured by the defendant. The specific unit used was from a lot later recalled due to the possible presence of silicone particulates. The plaintiff had a history of eye conditions and prior treatments but argued that her injuries followed the use of the recalled product. She presented two experts on causation: a retained ophthalmologist who provided a report and deposition, and her treating physician, who did not provide a written expert report.The Superior Court, Law Division, denied the defendant’s motions to bar the experts’ testimony and for summary judgment. The court did not conduct the “gatekeeping” inquiry regarding expert reliability required by New Jersey law. The defendant appealed, and the Appellate Division reversed. It found the experts’ opinions to be inadmissible net opinions, lacking evidentiary support for the proposed theory of causation and methodology. The Appellate Division thus also reversed the denial of summary judgment, holding the plaintiff had not established causation.The Supreme Court of New Jersey reviewed the case and held that its decision in In re Accutane Litigation requires trial courts to resolve disputes about the reliability of expert testimony by undertaking a “rigorous” gatekeeping analysis, potentially including a hearing under N.J.R.E. 104. The Supreme Court found the record insufficient for this determination and ordered a remand so the trial court could conduct the proper reliability inquiry. The Court held the retained expert’s report was not a net opinion but left open whether the treating physician’s testimony could be admitted, depending on whether a proper expert report is served. The Supreme Court reversed the Appellate Division’s judgment and remanded the matter to the trial court for proceedings consistent with its opinion. View "Beavan v. Allergan U.S.A., Inc." on Justia Law

Jeffrey Olson leased a Jeep Grand Cherokee from a car dealership under a lease agreement that included an arbitration provision and a delegation clause, which assigned questions about the scope of arbitration to an arbitrator. FCA US, LLC, the manufacturer of the Jeep, was not a signatory to the lease agreement. Olson later became the named plaintiff in a federal class-action lawsuit against FCA, alleging defects in the vehicle’s headrest system. FCA, not being a party to the lease, sought to compel Olson to arbitrate the dispute based on the arbitration agreement between Olson and the dealership.The United States District Court for the Eastern District of California denied FCA’s motion to compel arbitration. The district court found that FCA, as a non-signatory to the lease agreement, could not enforce the arbitration provision or its delegation clause against Olson. The court concluded that the arbitration agreement applied only to Olson and the dealership (including its employees, agents, successors, or assigns), and FCA did not qualify under any of those categories. Additionally, the court rejected FCA’s argument that it could use equitable estoppel to compel arbitration, holding that none of Olson’s claims were sufficiently intertwined with the lease agreement to justify such an exception under California law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that FCA could not compel Olson to arbitrate because FCA was not a party to the arbitration agreement and no applicable exception—such as equitable estoppel—applied. The court clarified that, under both federal and California law, only parties to an arbitration agreement (or those qualifying under specific, limited exceptions) may enforce it. The court also rejected FCA’s reliance on Supreme Court precedent, finding it inapplicable to non-signatories in these circumstances. View "OLSON V. FCA US, LLC" on Justia Law

Whittaker, Clark & Daniels, Inc. and three affiliates, with a history of manufacturing, storing, and distributing asbestos-containing talc, faced thousands of personal injury and environmental claims. After a $29 million verdict against Whittaker in South Carolina, a state court there appointed a receiver to administer Whittaker’s assets. Whittaker’s board, without consulting the receiver, authorized and filed a Chapter 11 bankruptcy petition in the United States Bankruptcy Court for the District of New Jersey. The Debtors’ estates were largely depleted by a 2004 asset sale to Brenntag, which expressly excluded liability for pre-sale asbestos and environmental claims. The Debtors, now essentially shells, sought to settle successor liability claims against Brenntag for $535 million, but some talc claimants had already asserted such claims against Brenntag in state courts.The South Carolina receiver and the Official Committee of Talc Claimants challenged the bankruptcy filing’s validity, arguing that only the receiver could authorize such a filing under the South Carolina court's order. The receiver’s motion to dismiss the bankruptcy petition as unauthorized was denied by the Bankruptcy Court, which found the South Carolina order did not divest Whittaker’s board of its authority. The United States District Court for the District of New Jersey affirmed. In parallel, the Committee contested whether certain “product-line” successor liability claims belonged to the Debtors’ estates or to individual creditors. The Bankruptcy Court, referencing Third Circuit precedent, held that such claims were property of the bankruptcy estates.The United States Court of Appeals for the Third Circuit affirmed both lower court decisions. It held that Whittaker’s Chapter 11 filing was valid, as the South Carolina court’s receivership order did not displace the board’s authority under New Jersey law, which governs corporate internal affairs. The court further held that successor liability claims based on product-line theory, even if nominally assertable by creditors outside bankruptcy, are property of the bankruptcy estate when they address a general injury to the debtor that results in secondary harm to all creditors. Accordingly, the judgments below were affirmed. View "In re Whittaker, Clark & Daniels Inc" on Justia Law

A worker at the Cherry Point oil refinery in Washington was regularly exposed to asbestos-containing insulation during his employment, which began in 1971. The insulation at issue was chosen, supplied, and installed by a subcontractor as part of the refinery’s original construction in the early 1970s. Decades after his exposure, the worker developed mesothelioma and died from the disease. His estate brought claims against numerous defendants, including the subcontractor, based on alleged asbestos exposure at the refinery.The Whatcom County Superior Court first granted summary judgment for the subcontractor, relying on Maxwell v. Atlantic Richfield Co., which held that Washington’s six-year construction statute of repose barred such claims. However, the court reconsidered and denied summary judgment after the Washington Court of Appeals issued Welch v. Brand Insulations, Inc., which found there were factual questions about whether the subcontractor’s activities were covered by the statute of repose. Due to conflicting appellate decisions, the Supreme Court of Washington granted direct review.The Supreme Court of the State of Washington held that claims against the subcontractor arising from its construction activities—specifically, its installation of asbestos insulation as part of constructing an improvement on real property—are barred by the construction statute of repose. However, the court held that claims based on the subcontractor’s independent role as a product seller or supplier, separate from its construction activities, are not barred by the statute of repose. The court affirmed in part, reversed in part, and remanded the case for further proceedings to determine which claims, if any, survive under theories of product seller or supplier liability. The court declined to address the constitutionality of the statute of repose, as that issue was not timely raised. View "Polinder v. Aecom Energy & Constr., Inc." on Justia Law