Justia Products Liability Opinion Summaries

James Ethridge, a Texas resident, purchased a Samsung 18650 lithium-ion battery from a Wyoming-based seller on Amazon in October 2018. The battery exploded in his pocket in November 2019, causing severe burns and other injuries. Ethridge filed a personal injury lawsuit in Texas state court in 2021 against Samsung SDI Company, Firehouse Vapors LLC, and two Amazon entities. He later added Macromall LLC as a defendant. After dismissing Firehouse Vapors, the remaining defendants removed the case to federal court. Ethridge then dismissed Macromall, leaving Samsung and the Amazon entities as defendants.The United States District Court for the Southern District of Texas granted summary judgment in favor of the Amazon defendants and dismissed Samsung for lack of personal jurisdiction. Ethridge appealed the dismissal of Samsung to the United States Court of Appeals for the Fifth Circuit, voluntarily dismissing his appeal against Amazon.The Fifth Circuit reviewed the district court's decision de novo and reversed the dismissal. The court held that Samsung had purposefully availed itself of the Texas market by shipping 18650 batteries to companies like Black & Decker, HP, and Dell in Texas. The court found that Ethridge's claims were related to Samsung's contacts with Texas, as the same type of battery that injured Ethridge was sold in Texas. The court concluded that exercising personal jurisdiction over Samsung in Texas was fair and reasonable, given the state's interest in providing a forum for its injured residents and Samsung's ability to litigate in Texas. The case was remanded for further proceedings. View "Ethridge v. Samsung SDI" on Justia Law

The plaintiffs, a group of individuals and entities associated with the Daughtry family, sued Silver Fern Chemical, Inc. and its employee, Gilda Franco. Silver Fern supplied the plaintiffs with a chemical called 1,4 butanediol (BDO), which can be used as a date-rape drug. The Drug Enforcement Administration (DEA) investigated the distribution of BDO for illicit use and subpoenaed Silver Fern for emails related to BDO purchases. Franco altered these emails to include a Safety Data Sheet (SDS) that was not originally attached, and the plaintiffs allege this was done to aid the government in prosecuting them.The United States District Court for the Eastern District of Texas dismissed the claims against Franco for lack of personal jurisdiction and against Silver Fern for failure to state a claim. The court found that the plaintiffs did not adequately allege that Silver Fern intended for them to rely on the altered emails, nor did they show reliance on these emails to their detriment. The court also dismissed the products-liability claims, stating that the plaintiffs were not the end users of the chemical and did not suffer physical harm.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the fraud claims, agreeing that the plaintiffs failed to show that Silver Fern intended for them to rely on the altered emails. The court also upheld the dismissal of the civil conspiracy to commit fraud claim, as it was dependent on the underlying fraud claim. Additionally, the court affirmed the dismissal of the products-liability claims, noting that the plaintiffs did not suffer physical harm and were not the end users of the chemical.The Fifth Circuit concluded that the district court's judgment of dismissal was correct and affirmed the decision. View "Daughtry v. Silver Fern Chemical" on Justia Law

Oscar Hernandez allegedly sustained injuries from a RIDGID-branded nail gun purchased from Home Depot. The nail gun, designed and manufactured by other companies, was marketed and sold by Home Depot under a trademark license agreement with Ridge Tool Company. Hernandez filed a complaint against Ridge Tool Company and Home Depot, asserting claims of strict liability, negligence, breach of express warranty, and breach of implied warranty of fitness. The case was removed to the U.S. District Court for the District of Nevada.The respondents moved for summary judgment, arguing that Ridge Tool Company should not be held strictly liable as it only licensed the RIDGID trademark and did not participate in the design, manufacture, distribution, or sale of the nail gun. The U.S. District Court granted summary judgment on all claims except the strict liability claim, noting the lack of controlling precedent in Nevada on whether a trademark licensor can be held strictly liable under such circumstances. The court certified the question to the Supreme Court of Nevada.The Supreme Court of Nevada concluded that Nevada does not impose strict products liability on an entity whose only involvement with a defective product is licensing its trademark for marketing purposes. The court adopted the rule set forth in section 14 of the Restatement (Third) of Torts: Products Liability, which states that a trademark licensor is not subject to strict liability unless it substantially participates in the design, manufacture, or distribution of the product. The court answered the certified question in the negative, holding that a trademark licensor cannot be held strictly liable for damages caused by a defective product if its role is limited to licensing its trademark. View "HERNANDEZ VS. THE HOME DEPOT, INC." on Justia Law

William D. Lunn, individually and as the representative of the estates of his three deceased children, filed a wrongful death lawsuit against Continental Motors, Inc. (CMI) in October 2009, alleging a design defect caused an airplane crash that killed his children. In September 2012, CMI made an unapportioned offer of judgment for $300,000, which Lunn rejected. After a lengthy litigation process, a jury found in favor of CMI. Lunn moved for a new trial, which the district court granted in February 2021. CMI appealed, arguing the claims were barred by the statute of repose under the General Aviation Revitalization Act. The Court of Civil Appeals (COCA) reversed the district court's decision.CMI then sought attorney's fees, claiming entitlement under the offer of judgment statute since the judgment was less than their offer. The district court denied the motion, ruling the unapportioned offer invalid. CMI appealed this decision. COCA affirmed the district court's ruling, referencing prior cases that required offers of judgment to be apportioned among plaintiffs to be valid.The Supreme Court of the State of Oklahoma reviewed the case to address whether an offer of judgment under 12 O.S.2021, § 1101.1(A) must be apportioned among multiple plaintiffs. The court held that such offers must indeed be apportioned to allow each plaintiff to independently evaluate the settlement offer. The court emphasized that unapportioned offers create confusion and hinder the plaintiffs' ability to assess the offer's value relative to their claims. Consequently, the court vacated COCA's opinion and affirmed the district court's judgment, ruling CMI's unapportioned offer invalid. View "Lunn v. Continental Motors, Inc." on Justia Law

Marquise Johnson was injured when his friend, André Lewis, accidentally shot him while attempting to disassemble a handgun in a car. Lewis believed the gun could not fire without the magazine, but it discharged, hitting Johnson in the legs. Johnson sued the gun's manufacturer, importer, and seller, alleging the gun was defective for lacking certain safety features.The Lyon District Court granted summary judgment to the defendants, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which provides immunity to firearm manufacturers and sellers from lawsuits when their products are misused criminally. The court found that Lewis' act of pulling the trigger was volitional and constituted a criminal offense under Kansas law, specifically the strict-liability crime of discharging a firearm on a public road.The Kansas Court of Appeals reversed the district court's decision, interpreting the PLCAA to require an intentional discharge for immunity to apply. The majority held that because Lewis did not intend to fire the gun, the PLCAA did not bar Johnson's lawsuit. A dissenting judge argued that the PLCAA should apply because Lewis' act of pulling the trigger was volitional.The Kansas Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that the PLCAA bars product-liability actions if a volitional act causes the gun to discharge and the shooting constitutes a criminal offense. The court found that Lewis' deliberate trigger pull was a volitional act and that discharging a firearm on a public road is a strict-liability crime under Kansas law. Therefore, the PLCAA provided immunity to the defendants, and the district court's summary judgment was affirmed. The case was remanded to the district court. View "Johnson v. Bass Pro Outdoor World " on Justia Law

In 2018, a $200 million mixed-use development project at Louisiana State University experienced issues with its fire-protection sprinkler systems, which began to crack and leak. Allied World National Assurance Company, which paid over $10 million for system replacements, sued Nisus Corporation in 2021, alleging that Nisus falsely represented its product's compatibility with the pipe material, leading to the damage.The United States District Court for the Middle District of Louisiana granted summary judgment in favor of Nisus, concluding that Allied's claims were time-barred under Louisiana law. The court found that while Provident, the insured party, did not have actual or constructive knowledge of the cause of the damage, RISE Residential, Provident's agent, had constructive knowledge of the cause by November 2019. This knowledge was imputed to Provident, starting the prescription period.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that RISE Residential's constructive knowledge of the sprinkler system issues, which was imputed to Provident, triggered the running of the prescription period well before July 23, 2020. The court also found that Nisus did not prevent Allied from timely availing itself of its causes of action, as a reasonable inquiry by RISE Residential would have uncovered the necessary information. Therefore, Allied's claims were prescribed, and the summary judgment in favor of Nisus was affirmed. View "Allied World National v. Nisus" on Justia Law

Plaintiffs alleged that an automobile manufacturer designed, manufactured, and sold defective vehicles, specifically Dodge "muscle" cars with defective rear differentials. They filed a complaint asserting state and federal causes of action based on fraud and breach of warranty. The District Court dismissed the fraud counts and some warranty counts, allowing plaintiffs to amend their complaint. After amending, the District Court dismissed the fraud counts again and some warranty counts, but allowed two warranty counts to proceed.The United States District Court for the District of Delaware initially dismissed the complaint without prejudice, allowing plaintiffs to amend it. After the plaintiffs amended their complaint, the District Court dismissed the fraud counts and some warranty counts with prejudice, but allowed two warranty counts to proceed. The plaintiffs then moved to certify the dismissal of their fraud counts for appeal under 28 U.S.C. § 1292(b) or for final judgment under Rule 54(b). The District Court denied the request for certification under § 1292(b) but granted the request for final judgment under Rule 54(b) for the fraud counts.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the District Court's Rule 54(b) judgment was not final. The Court of Appeals held that the fraud and warranty counts constituted a single claim for purposes of Rule 54(b) because they were alternative theories of recovery based on the same factual situation. As a result, the judgment did not dispose of all the rights or liabilities of one or more of the parties. Consequently, the Court of Appeals dismissed the appeal for lack of jurisdiction and instructed the District Court to vacate its order directing the entry of a partial final judgment. View "Diaz v. FCA US LLC" on Justia Law

Charter Oak Production Co., LLC paid to settle a property damage claim after a pipeline installed on its easement ruptured, causing a saltwater spill on the property of Jason and Melissa Mills. Charter Oak sought indemnity from JM Eagle, Inc., the manufacturer, and Rainmaker Sales, Inc., the distributor, alleging the pipe was defective. The district court granted summary judgment in favor of JM Eagle and Rainmaker, finding that Charter Oak lacked the necessary legal relationship to assert an indemnity claim and that the claim was barred by the economic loss rule.The Oklahoma Court of Civil Appeals, Division IV, reversed the district court's decision. It found that Charter Oak's non-delegable duty to the Millses created the legal relationship necessary to support an indemnity claim against JM Eagle and Rainmaker. Additionally, it held that Charter Oak's claim was not barred by the economic loss rule.The Supreme Court of the State of Oklahoma reviewed the case. It held that Charter Oak's non-delegable duty as the dominant tenant of the easement established the legal relationship necessary to seek indemnity from JM Eagle and Rainmaker. The court also held that the economic loss rule did not bar Charter Oak's indemnity claim, as it sought reimbursement for damage to property other than the defective product itself. Consequently, the Supreme Court vacated the Court of Civil Appeals' decision, reversed the district court's order, and remanded the case for further proceedings consistent with its opinion. View "Mills v. J-M Mfg. Co., Inc." on Justia Law

Darnell Hairston was seriously injured while operating machinery at Zeeland Farm Soya, Inc. He sued Zeeland Farm Services, Inc. (ZFS) and an employee, later adding Specialty Industries, Inc. as a defendant for negligence and products liability. ZFS settled, but the case against Specialty Industries proceeded to trial, resulting in a jury awarding Hairston over $13 million. Specialty Industries had insurance policies with Burlington Insurance Company and Evanston Insurance Company, which paid their policy limits, leaving a significant portion of the judgment unpaid.The Ottawa Circuit Court denied Hairston and Specialty Industries' motion for supplemental proceedings to pursue a bad-faith refusal to settle claim against the insurers, suggesting they file a separate lawsuit. Hairston then served writs of garnishment on the insurers, which the trial court quashed, stating there was no judgment of bad faith. The trial court also imposed sanctions on Hairston for filing the writs.The Michigan Court of Appeals reversed the trial court's decision to quash the writs, relying on the precedent set in Rutter v King, which allowed bad-faith refusal to settle claims to be litigated through garnishment. However, the Court of Appeals affirmed the sanctions against Hairston.The Michigan Supreme Court reviewed the case and held that unresolved claims of bad-faith refusal to settle are not subject to garnishment under MCR 3.101(G)(1) because they are not sufficiently liquidated. The Court found that the Court of Appeals erred in relying on Rutter, which was decided before the current court rules were adopted. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "Hairston v. Lku" on Justia Law

In March 2016, thirteen-year-old J.R. Gustafson was accidentally shot and killed by his fourteen-year-old friend at a residence in Mt. Pleasant, Pennsylvania. J.R.'s parents, Mark and Leah Gustafson, filed a lawsuit against Springfield Armory, the manufacturer of the firearm, and Saloom Department Store, the retailer that sold the firearm. They alleged defective design, negligent design and sale, and negligent warnings and marketing. The trial court dismissed the complaint with prejudice, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which bars certain civil actions against firearms manufacturers and sellers.The Gustafsons appealed, and the Superior Court reversed the trial court's decision, remanding the case for further proceedings. The Superior Court's en banc panel issued a per curiam order, with no single rationale garnering majority support. Some judges found the PLCAA barred the claims but was unconstitutional, while others found the PLCAA did not bar the claims or was constitutional. The Superior Court's order was challenged, leading to the current appeal.The Supreme Court of Pennsylvania reviewed the case and determined that the PLCAA barred the Gustafsons' action. The court found that the action constituted a "qualified civil liability action" under the PLCAA, as it was a civil action against a manufacturer and seller of a qualified product for damages resulting from the criminal or unlawful misuse of a firearm. The court also concluded that the product liability exception did not apply because the discharge of the firearm was caused by a volitional act that constituted a criminal offense.The court further held that the PLCAA was a valid exercise of Congress's Commerce Clause authority and did not violate the Tenth Amendment or principles of federalism. Consequently, the Supreme Court of Pennsylvania vacated the Superior Court's order and remanded the case for reinstatement of the trial court's dismissal of the Gustafsons' complaint. View "Gustafson v. Springfield, Inc." on Justia Law