Justia Products Liability Opinion Summaries

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

Plaintiffs MSP Recovery Claims, Series LLC; MSPA Claims 1, LLC; and Series PMPI filed a lawsuit in September 2018 against Fresenius Medical Care Holdings and related entities, alleging negligence, product liability, and design defect claims related to the GranuFlo product used in hemodialysis treatments. The claims arose from a 2012 public memorandum by Fresenius that GranuFlo could lead to cardiopulmonary arrest. The plaintiffs argued that the statute of limitations was tolled by a putative class action filed in 2013 (the Berzas action) in the Eastern District of Louisiana, which was later transferred to the District of Massachusetts as part of multidistrict litigation (MDL).The District Court for the District of Massachusetts dismissed the plaintiffs' claims as time-barred, concluding that the Berzas action ceased to be a class action by June 2014 when the named plaintiffs filed Short Form Complaints or stipulations of dismissal, which did not include class allegations. The court also noted that the Berzas plaintiffs did not pursue class certification actively, and the case was administratively closed in April 2019.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The First Circuit held that the Berzas action lost its class action status by June 2014, and any tolling under American Pipe & Construction Co. v. Utah ended at that time. The court reasoned that allowing indefinite tolling based on an inactive class certification request would contravene the principles of efficiency and economy in litigation. Therefore, the plaintiffs' 2018 complaint was untimely, and the district court's dismissal was upheld. View "MSP Recovery Claims, Series LLC v. Fresenius Medical Care Holdings, Inc." on Justia Law

Plaintiffs, who were allegedly sexually assaulted or harassed by Uber drivers, filed individual lawsuits against Uber Technologies, Inc. across various districts. They claimed Uber failed to take reasonable measures to prevent such misconduct, asserting negligence, misrepresentation, products liability, and vicarious liability. Plaintiffs argued that Uber was aware of the issue since at least 2014 but did not implement adequate safety measures, such as proper background checks, emergency notifications, and effective responses to complaints.The Judicial Panel on Multidistrict Litigation (JPML) centralized these cases in the Northern District of California for coordinated pretrial proceedings under 28 U.S.C. § 1407. Uber opposed the centralization, arguing that their terms of use included a collective action waiver that precluded such a transfer and that the cases did not share sufficient common factual questions to warrant centralization. The JPML found that the cases did involve common factual questions and that centralization would eliminate duplicative discovery, prevent inconsistent pretrial rulings, and conserve resources.The United States Court of Appeals for the Ninth Circuit reviewed Uber's petition for a writ of mandamus challenging the JPML's order. The court held that Uber had not demonstrated that the JPML committed a clear error of law or a clear abuse of discretion. The court found that the JPML acted within its broad discretion in determining that the cases presented common questions of fact and that centralization would promote the just and efficient conduct of the actions. The court also rejected Uber's argument regarding the collective action waiver, stating that Section 1407 grants the JPML the authority to centralize cases regardless of private agreements to the contrary. Consequently, the Ninth Circuit denied Uber's petition for a writ of mandamus. View "UBER TECHNOLOGIES, INC. V. UNITED STATES JUDICIAL PANEL ON MULTIDISTRICT LITIGATION" on Justia Law

Vernon Holland was fatally injured by a rewinder machine at his workplace. Robert Cearley, Jr., representing Holland’s estate, filed a wrongful death lawsuit against Bobst Group North America, Inc. (Bobst NA), the company responsible for delivering and installing the rewinder. The lawsuit sought damages based on several tort claims.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Bobst NA. The court ruled that Arkansas’s statute of repose, which limits the time frame for bringing claims related to construction or design defects, barred Cearley’s claims. Cearley appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether Bobst NA was protected under Arkansas Code § 16-56-112(b)(1), which is a statute of repose for claims arising from personal injury or wrongful death caused by construction defects. The court concluded that Bobst NA’s involvement in the delivery, installation, integration, and commissioning of the rewinder constituted the construction of an improvement to real property. The court also determined that the rewinder was an improvement to real property because it was affixed to the plant, furthered the purpose of the realty, and was designed for long-term use.As the lawsuit was filed more than four years after the installation of the rewinder, the court held that the claims were barred by the statute of repose. Consequently, the Eighth Circuit affirmed the district court’s judgment in favor of Bobst NA. View "Cearley v. Bobst Group North America Inc." on Justia Law

James Wilson III used earplugs manufactured by Hearos, LLC at a shooting range and subsequently suffered significant hearing loss. He filed a lawsuit against Hearos in state court, alleging various tort claims. Protective Industrial Products, Inc. (PIP), a non-party, removed the case to federal court. The district court noted the unusual removal by a non-party but proceeded as neither Wilson nor Hearos objected to the court's jurisdiction. The district court dismissed Wilson's claims as time-barred under Georgia law.The district court for the Southern District of Georgia found that Wilson filed his complaint three days before the statute of limitations expired but did not serve Hearos until 117 days after the limitations period ended. The court concluded that Wilson failed to demonstrate the required diligence in serving Hearos, leading to the dismissal of his claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that removal by a non-party is a procedural defect, not a jurisdictional one, and must be objected to within 30 days under 28 U.S.C. § 1447(c). Since Wilson did not object within this period, he waived his right to challenge the removal. The court also affirmed that Georgia's service-and-diligence rule, rather than Federal Rule of Civil Procedure 4(m), applied to determine if Wilson's claims were time-barred. The court concluded that Wilson did not act with the required diligence to serve Hearos, affirming the district court's dismissal of his claims. View "Wilson v. Hearos, LLC" on Justia Law

An underage user of the Grindr application, John Doe, filed a lawsuit against Grindr Inc. and Grindr LLC, alleging that the app facilitated his sexual exploitation by adult men. Doe claimed that Grindr's design and operation allowed him to be matched with adults despite being a minor, leading to his rape by four men, three of whom were later convicted. Doe's lawsuit included state law claims for defective design, defective manufacturing, negligence, failure to warn, and negligent misrepresentation, as well as a federal claim under the Trafficking Victims Protection Reauthorization Act (TVPRA).The United States District Court for the Central District of California dismissed Doe's claims, ruling that Section 230 of the Communications Decency Act (CDA) provided Grindr with immunity from liability for the state law claims. The court also found that Doe failed to state a plausible claim under the TVPRA, as he did not sufficiently allege that Grindr knowingly participated in or benefitted from sex trafficking.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that Section 230 barred Doe's state law claims because they implicated Grindr's role as a publisher of third-party content. The court also agreed that Doe failed to state a plausible TVPRA claim, as he did not allege that Grindr had actual knowledge of or actively participated in sex trafficking. Consequently, Doe could not invoke the statutory exception to Section 230 immunity under the Allow States and Victims to Fight Online Sex Trafficking Act of 2018. The Ninth Circuit affirmed the district court's dismissal of Doe's claims in their entirety. View "DOE V. GRINDR INC." on Justia Law

The plaintiffs sought to recover damages from the defendants for alleged violations of the Connecticut Product Liability Act (CPLA) after their minor child, L.L., was severely injured. The injury occurred when a Graco car seat, placed on a kitchen counter next to an electric range stove, caught fire. The plaintiffs claimed that the car seat and stove were defectively designed or manufactured. As a result of the fire, L.L. suffered severe burns and injuries. The plaintiffs, including L.L.'s parents, also sought damages for loss of filial consortium, alleging that they lost the society, care, and companionship of their daughter due to her injuries.The United States District Court for the District of Connecticut reviewed the case and certified a question to the Connecticut Supreme Court, asking whether Connecticut law recognizes a parent's claim for loss of filial consortium when a minor child suffers severe but nonfatal injuries due to a defendant's tortious conduct. The District Court had previously denied the defendants' motion to dismiss the loss of consortium claims without prejudice.The Connecticut Supreme Court concluded that Connecticut law does not recognize a cause of action for loss of filial consortium. The court reasoned that the justifications for recognizing loss of spousal and parental consortium claims, which are based on mutual dependence and reliance, do not apply to the parent-child relationship in the same way. The court emphasized that the emotional distress experienced by a parent due to a child's severe injury is distinct from the relational loss addressed by loss of consortium claims. The court found the reasoning of jurisdictions that distinguish between parental and filial consortium more persuasive and declined to expand the scope of liability to include loss of filial consortium. View "L. L. v. Newell Brands, Inc." on Justia Law