Justia Products Liability Opinion Summaries

The case involves an injury sustained by an individual while operating a forklift designed, manufactured, and distributed by a company. The injured party alleged that the forklift’s open operator compartment constituted a defective design, making the product unreasonably dangerous, and asserted that adding features such as a door or bumper would have prevented the accident. To support these claims, the injured party retained an expert witness to testify about the alleged defect and alternative, safer designs.In the Circuit Court of Jackson County, the defendant company filed motions both to exclude the plaintiff’s expert witness and for summary judgment. The court found that the expert’s testimony lacked reliability, as the plaintiff failed to demonstrate that the expert’s opinions were based on reliable principles and methods, or that those methods had been properly applied to the facts. The court noted the absence of relevant testing, peer-reviewed support, or clear connection between the expert’s analysis and the incident. Consequently, the court excluded the expert’s testimony. Without admissible expert evidence to support the defective design claim, the circuit court then granted summary judgment for the company, as there was no genuine issue of material fact.On appeal, the Supreme Court of Missouri reviewed only the grant of summary judgment. The court held that the circuit court did not abuse its discretion in excluding the expert’s testimony under section 490.065, as the plaintiff failed to establish the reliability of the expert’s methods or their application to the case. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that without admissible expert testimony, summary judgment was proper, including as to the punitive damages claim, because the plaintiff could not prevail on the underlying product liability claim. View "Hanshaw v. Crown Equipment Corp." on Justia Law

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period.This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

The parents of a young child in Texas purchased and fed him baby food manufactured by one company and sold by another. After the child began exhibiting serious developmental and physical disorders, doctors attributed his condition to heavy-metal poisoning. Years later, a congressional subcommittee released a report identifying elevated levels of toxic heavy metals in certain baby foods, including that manufactured by the company in question. The parents then sued both the manufacturer and the retailer in Texas state court, alleging various state-law product liability, negligence, and breach-of-warranty claims.The manufacturer, a Delaware corporation with its principal place of business in New York, removed the case to federal court, arguing that the retailer—a Texas citizen like the plaintiffs—had been improperly joined and should be dismissed, thereby creating complete diversity. The United States District Court agreed, dismissed the retailer, denied the plaintiffs’ motion to remand, and proceeded to trial against the manufacturer alone. After trial, the District Court granted judgment as a matter of law to the manufacturer. On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the District Court’s finding of improper joinder, reversed the dismissal of the retailer, and concluded that because the retailer was a proper party, complete diversity was lacking. The Fifth Circuit vacated the judgment and remanded the case to state court.The Supreme Court of the United States held that the District Court’s erroneous dismissal of the nondiverse defendant did not cure the jurisdictional defect present at the time of removal. Because the jurisdictional defect was not cured and persisted through final judgment, the federal court’s judgment had to be vacated. The Supreme Court affirmed the Fifth Circuit’s decision and remanded the case for further proceedings. View "Hain Celestial Group, Inc. v. Palmquist" on Justia Law

This case involves four individuals who died by suicide after ingesting high-purity sodium nitrite purchased through Amazon’s website. The families and estates of the decedents allege that Amazon sold sodium nitrite without age verification or adequate warnings, promoted related products that facilitated suicide, and continued selling the chemical despite knowing it was being used for suicide. Plaintiffs contend that Amazon’s actions enhanced the risk of harm and demonstrated knowledge of the product’s misuse, citing Amazon’s receipt of warnings from consumers, regulatory agencies, and the removal of the product in other jurisdictions.The Superior Court denied Amazon’s motions to dismiss under CR 12(b)(6), finding that the plaintiffs had sufficiently stated a claim for negligence under the Washington Product Liability Act (WPLA). On appeal, the Court of Appeals, Division One, reversed this decision. The appellate court concluded that, under Washington law, suicide is typically a superseding cause that breaks the chain of proximate causation for negligence, barring recovery unless the suicide was involuntary or due to an uncontrollable impulse. Relying on precedent, the appellate court held that plaintiffs could not state a WPLA claim because suicide was a superseding cause as a matter of law.The Supreme Court of the State of Washington reviewed the case de novo. It determined that common law principles of negligence and proximate cause, including those developed after the WPLA’s enactment, govern product seller liability claims. The court held that, at the motion to dismiss stage, it cannot be said as a matter of law that suicide is always a superseding cause precluding liability under the WPLA. The court concluded that plaintiffs alleged sufficient facts to state a claim for product seller negligence, as questions of foreseeability and proximate cause are generally issues for the fact finder. The court reversed the Court of Appeals and reinstated the trial court’s denial of Amazon’s motions to dismiss. View "Scott v. Amazon.com, Inc." on Justia Law

The plaintiff purchased a vehicle in 2017 and later alleged it was defective, suing the manufacturer in 2021. The parties eventually settled, with the plaintiff surrendering the vehicle and dismissing the suit, and the manufacturer agreeing to pay $100,000. The settlement specified the plaintiff would be deemed the prevailing party for purposes of attorney fees, and the manufacturer would pay the amount determined by the trial court upon noticed motion. After the settlement was reported to the Superior Court of San Diego County, the court ordered dismissal within 45 days. When no dismissal was filed, the clerk issued notice that the case would be deemed dismissed without prejudice on August 15, 2023, unless a party showed good cause otherwise. No such cause was shown, and the plaintiff subsequently filed a motion for attorney fees.The motion for attorney fees was opposed by the manufacturer, arguing it was untimely under California Rules of Court, as it was not served within 180 days of the dismissal date. The plaintiff countered that the 180-day deadline did not apply, claiming the case had not been formally dismissed and no judgment had been entered. The Superior Court of San Diego County disagreed, finding the case had been dismissed on August 15, 2023, per the clerk’s notice and court rules, and denied the motion as untimely. The plaintiff appealed the denial, and a signed minute order dismissing the complaint was later entered, but the court maintained that the earlier date controlled.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the matter de novo. It held that a voluntary dismissal, even if not appealable, starts the clock for filing a motion for attorney fees when it concludes the litigation. The court found the case was dismissed on August 15, 2023, and the plaintiff failed to timely serve the fee motion. The order denying attorney fees was affirmed. View "Hatlevig v. General Motors LLC" on Justia Law

A laser-cutting system operator died after being trapped between components of an industrial laser-cutting system when a steel beam descended into a gap, resulting in fatal injuries. The system, designed, sold, installed, and maintained by one company, consisted of several components, including a material handler, load frame, and main frame. On the day of the incident, the operator entered a narrow gap between the material handler and the load frame; when the system was activated, a steel beam pinned him, leading to his death. There were multiple possible routes into the gap, and prior incidents indicated the operator had previously entered the area. The estate of the deceased operator sued the designer and installer for negligent design, negligent installation, breach of warranty of merchantability (based on design and manufacturing defects), and negligent failure to maintain and warn of dangerous conditions.The case was initially filed in state court, then removed to the United States District Court for the District of Massachusetts. After discovery, the district court granted summary judgment to the defendant on all claims. The district court found that the system included a barrier fence at installation, making the system adequately protected and negating breach of warranty or negligent design claims. For the claims related to maintenance and failure to warn, the court found no triable issue on causation, as there was insufficient evidence that the operator had entered the gap through the unguarded wall-side opening.On appeal, the United States Court of Appeals for the First Circuit vacated the district court’s summary judgment on the design-related claims, finding a genuine factual dispute as to whether a reasonable alternative design—such as additional safety devices—could have mitigated the system’s risks. However, the appellate court affirmed summary judgment on the installation, maintenance, and failure to warn claims, concluding there was insufficient evidence to establish causation for those theories. The case was remanded for further proceedings on the design claims. View "Alicea v. Cincinnati Incorporated" on Justia Law

A woman suffered a below-the-knee amputation of her left leg after an accident involving a zero-radius-turn riding lawnmower manufactured by The Toro Company. The incident occurred when the mower, which could be disengaged from its hydrostatic braking system using "bypass pins," began rolling uncontrolled down a slope after the pins were not reset following an attempt to free the mower from a flower bed. The mower lacked an independent mechanical brake, a rollover protection system, and an ignition safety interlock that would have prevented operation with the bypass engaged. The injured woman, her spouse, and their minor child pursued damages for her injuries, claiming design defects and failure to warn.The suit was filed in the United States District Court for the Central District of Illinois. During pretrial proceedings, the district court excluded all of the plaintiffs’ expert testimony as unreliable or irrelevant and granted summary judgment to Toro on all remaining theories. The court found that, without expert evidence, the plaintiffs could not establish their strict products liability or negligent design claims. It also dismissed the failure-to-warn claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed most of the district court’s evidentiary rulings but found that the district court did not address one expert’s opinions regarding the need for an independent brake. The appellate court held those opinions to be reliable and relevant, thus presenting genuine disputes of material fact regarding the absence of an independent brake. Consequently, it reversed the summary judgment for Toro on the strict products liability and negligent design claims related to the independent brake theory, affirmed in all other respects, and remanded the case for trial. View "Hillman v. Toro Company" on Justia Law

A Nevada resident was injured when a lithium-ion battery exploded in his pocket, causing severe burns. He had purchased the battery individually from a local vape shop, with no warnings or instructions provided. The battery in question was manufactured by a South Korean company and its American subsidiary, which design and sell these batteries as industrial components intended for integration into products such as power tools, not for standalone consumer use. Despite efforts by the manufacturer to prevent individual sales and warn against improper use—including sending cease-and-desist letters and posting warnings online—third-party retailers in the United States, including Nevada, sold the batteries individually.After the injury, the plaintiff filed a products liability suit in Nevada’s Eighth Judicial District Court against the manufacturer and its subsidiary. The defendants moved to dismiss for lack of personal jurisdiction, arguing that they did not sell or market individual batteries for standalone use in Nevada. The district court agreed, finding that the plaintiff failed to demonstrate that his injuries arose out of or were related to the manufacturer’s contacts with Nevada, and dismissed the case. The dismissal was certified as final, and the plaintiff appealed.The Supreme Court of Nevada reviewed the case de novo. It held that, while the manufacturer purposefully availed itself of Nevada’s market by selling batteries as components for incorporation into end products, the plaintiff’s injuries resulted from a standalone battery acquired through a different, unauthorized stream of commerce. Because there was no evidence that the manufacturer placed individual battery cells into the Nevada consumer market, the court found no sufficient connection between the company’s forum contacts and the plaintiff’s injury. The Supreme Court of Nevada affirmed the district court’s dismissal for lack of personal jurisdiction. View "Franceschi v. LG Chem, LTD." on Justia Law

A minor child was injured in 2018 while playing on a piece of playground equipment called “Rocks and Ropes” at Meadowlark Elementary School in Cheyenne, Wyoming. The child’s parents, Scott and Heather Hunter, alleged that the equipment was defective and that the school failed in its supervision and medical care following the incident, as their daughter was diagnosed weeks later with a crushed vertebra. The Hunters sued Universal Precast Concrete, Miracle Recreation Equipment, Churchich Recreation Equipment, and Laramie County School District #1, alleging strict product liability, negligence, breach of warranty, and failure to warn.The case proceeded before the District Court of Laramie County. Due to extensive delays—including those caused by the COVID-19 pandemic—there were multiple changes to scheduling orders. The district court granted summary judgment in favor of the business defendants after excluding several of the Hunters’ expert witnesses under the Daubert standard, finding their testimony unreliable or irrelevant. The court denied summary judgment to the School District. After a mistrial was declared due to repeated improper conduct by the Hunters’ counsel during voir dire and opening statements, the district court dismissed the remaining claims against the School District with prejudice as a sanction for counsel’s actions and various procedural violations.The Supreme Court of the State of Wyoming affirmed the district court’s exclusion of the Hunters’ experts and the grant of summary judgment in favor of the business defendants, holding that the lower court properly performed its gatekeeping function and the Hunters failed to offer admissible evidence of a defect. However, the Supreme Court reversed the district court’s dismissal with prejudice, concluding that, while counsel’s conduct warranted sanctions, the extreme sanction of dismissal was not justified without prior warning or full consideration of lesser sanctions. The case was remanded for imposition of a lesser sanction. View "Hunter v. Universal Precast Concrete, Inc." on Justia Law

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law