Justia Products Liability Opinion SummariesArticles Posted in Minnesota Supreme Court
In re Polaris, Inc. v. Polaris, Inc.
The Supreme Court affirmed the judgment of the court of appeals denying a writ of prohibition sought by Polaris, Inc. to prevent disclosure of a report in the underlying product-liability lawsuit brought by Colby Thompson, holding that Polaris failed to demonstrate that it was entitled to the writ.Under federal consumer safety processes and policies Polaris was subject to a government safety investigation and potential enforcement action. To conduct an audit into its safety process and policies, Polaris retained outside counsel, who provided a thirty-two page report that included recommendations to improve compliance performance. In the underlying litigation with Thompson, Polaris inadvertently disclosed the audit report during discovery and then sought to claw the document back, asserting that it was protected by the attorney-client privilege. The district court denied the claw-back request but did permit redactions of the report's legal advice. Polaris' request for a writ of prohibition followed. The Supreme Court affirmed the denial of the writ, holding that the district court did not clearly err by finding that the predominant purpose of the report was business advice and was therefore discoverable. View "In re Polaris, Inc. v. Polaris, Inc." on Justia Law
Kedrowskib v. Lycoming Engines
The Supreme Court reversed the decision of the court of appeals affirming the decision of the district court granting judgment as a matter of law to Lycoming Engines on Mark Kedrowski's claim that a defective fuel pump manufactured by Lycoming caused the airplane he was piloting to lose power and crash, holding that the district court abused its discretion by excluding that opinion of Kedrowski's sole expert on causation.The jury returned a $27.7 million verdict for Kedrowski. Thereafter, the district court granted Lycoming's motion for judgment as a matter of law, concluding that the opinion of Kedrowski's sole causation expert lacked foundational reliability and that, without this opinion, Kedrowski's claims failed. The court of appeals affirmed. The Supreme Court reversed, holding that the court's evidentiary exclusion was overbroad and an abuse of discretion. The Supreme Court remanded the case for a new trial on liability. View "Kedrowskib v. Lycoming Engines" on Justia Law
Great Northern Insurance Co. v. Honeywell International, Inc.
Claims brought against the manufacturer of a component part of an improvement to real property fell under an exception to the ten-year statute of repose because the improvement was “machinery installed upon real property.” See Minn. Stat. 541.051.Appellant manufactured the motor in a home’s heat-recovery ventilator. Sixteen years after the ventilator was installed, a fire started in the ventilator, causing property damage to the home. Respondent, the insurer of the homeowners, brought this subrogation action against Appellant. The district court granted summary judgment for Appellant, concluding that the ten-year statute of response for improvements to real property barred every claim except the claim alleging a post-sale duty to warn, which claim it dismissed upon summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) under the plain language of section 541.051, the ventilator containing Appellant’s motor was “machinery installed upon real property,” and therefore, the court of appeals properly reinstated Respondent’s breach of warranty, negligence, and product liability claims; and (2) Appellant did not have a duty to warn consumers of its product’s alleged defect after the time of sale. View "Great Northern Insurance Co. v. Honeywell International, Inc." on Justia Law
Montemayor v. Sebright Products, Inc.
The Supreme Court reversed the district court’s grant of summary judgment in favor of Defendant in this products liability action, holding that this was a “close case” in which foreseeability must be resolved by the jury.Plaintiff was injured by a high-density extruder manufactured by Defendant. Plaintiff brought a products liability action against Defendant, alleging failure-to-warn and design-defect claims. The district court granted Defendant’s motion for summary judgment, concluding that Defendant did not owe a duty of care to Plaintiff because Plaintiff’s injury was not reasonably foreseeable. The court of appeals affirmed. The Supreme Court reversed and remanded, holding that, viewing all of the evidence and inferences arising from it in the light most favorable to Plaintiff, reasonable persons might differ as to the foreseeability of Plaintiff’s injury under the circumstances. View "Montemayor v. Sebright Products, Inc." on Justia Law