Justia Products Liability Opinion Summaries

Decedent's family (the Kings) sued Toyota and the local Toyota dealership after Decedent lost control of his Toyota, which rolled over several times. The Kings asserted that the Toyota's allegedly defective seat belt system caused Decedent's ejection from the car and his subsequent death. The jury returned a verdict in Toyota's favor, and the trial court signed a corresponding judgment. The Kings moved for a new trial, alleging that Toyota's counsel had violated the trial court's limine rulings. The trial court granted the Kings' motion. Toyota subsequently filed an original proceeding in the Supreme Court. At issue was whether an appellate court may, in an original proceeding, determine whether the reasonably specific and legally sound rationale of the trial court for ordering a new trial was actually true. The Court conditionally granted relief, holding (1) an appellate court may conduct a merits review of the basis for a new trial order after a trial court has set aside a jury verdict, and if the record does not support the trial court's rationale for ordering a new trial, the appellate court may grant mandamus relief; and (2) in this case, the trial court abused its discretion in granting a new trial. View "In re Toyota Motor Sales, U.S.A., Inc." on Justia Law

Rebecca B. McDonald, as administrator of the estate of her son Jeremy Wayne McDonald, sued Kubota Manufacturing of America Corporation, Kubota Corporation, and Kubota Tractor Corporation, asserting various claims after her son died as a result of injuries sustained when a Kubota lawnmower he was operating rolled over, pinning him underneath it. Following a three-week trial, the jury returned a verdict in favor of the Kubota defendants, and the trial court entered a judgment on that verdict. McDonald's subsequent motion for a new trial was denied by the trial court, and McDonald appealed to the Supreme Court, arguing that she was entitled to a new trial based on juror misconduct and errors the trial court made when instructing the jury. Finding no abuse of discretion nor errors at trial, the Supreme Court affirmed.View "McDonald v. Kubota Manufacturing of America Corporation et al. " on Justia Law

A group of Texas plaintiffs alleged that a corporation exposed two employees to chemicals that caused two of the employees' children to suffer from birth defects. The Superior Court judge excluded expert testimony as irrelevant under Delaware law because it would have been insufficient as a matter of Texas law. The judge did not reach the testimony's reliability under Delaware law. Because the plaintiffs waived their argument that California or Delaware substantive law applied, the Supreme Court affirmed the Superior Court judge's ruling that Texas substantive law applies. But before the Court could address whether a judge may consider substantive sufficiency when analyzing procedural admissibility, the case was remanded for the Superior Court judge to determine in the first instance whether the testimony at issue is excludable on reliability grounds.View "Tumlinson, et al. v. Advanced Micro Devices, Inc." on Justia Law

Plaintiffs brought two separate actions alleging that Hazel Smart died as a result of a defective catheter used in her dialysis treatment at Greater Waterbury Gambro HealthCare. The trial court consolidated the two actions, which brought claims sounding in negligence, medical malpractice, loss of consortium, and products liability. During pretrial proceedings, the trial court imposed monetary sanctions on Plaintiffs for failure to comply with a discovery order. Plaintiffs appealed. The appellate court dismissed the appeal for lack of subject matter jurisdiction, finding that the trial court's discovery order was not an appealable final judgment. The Supreme Court affirmed, holding that the appellate court properly dismissed the appeal, as the trial court's order did not constitute an appealable final judgment.View "Incardona v. Roer" on Justia Law

Plaintiffs, Nelson and Elaine Cruz, filed a complaint against the car dealership where Nelson purchased his vehicle (Ricky Smith), alleging that while Nelson was cleaning the inside of his minivan, both front airbags unexpectedly deployed, injuring him. Plaintiffs' complaint alleged negligence, strict products liability, negligent misrepresentation, and res ipsa loquitur. In addition, Elaine sought damages for loss of consortium. The trial justice granted Ricky Smith's motion for summary judgment on all counts. The Supreme Court affirmed, holding that the hearing justice properly granted summary judgment in Ricky Smith's favor on Nelson's claims of negligence and misrepresentation, and consequently, Elaine was barred from recovering damages for loss of consortium. View "Cruz v. DaimlerChrysler Motors Corp." on Justia Law

A concrete truck collided with a shuttle bus used to transport passengers between an airport and a rental car facility. A passenger who was injured during the collision and his wife filed an action against the bus owner, bus manufacturer, manufacturer of the bus windows, and franchisor of the rental car business. Plaintiffs based their claims in negligence and products liability, arguing that the bus was unsafe because it did not have passenger seatbelts, had windows made of tempered glass, and provided perimeter seating instead of forward-facing rows. A jury found Plaintiffs had sustained damages but assessed 100 percent of the fault to the corporate owner of the concrete truck, which had previously settled with Plaintiffs. On appeal, the court of appeals held that federal law preempted the seatbelt and window-glass claims and ruled that the trial court erred by failing to grant a directed verdict on the perimeter-seating claim. The Supreme Court remanded. On remand, the court of appeals affirmed its prior judgment. The Supreme Court reversed, holding (1) the seatbelt and window-glass claims were not preempted by federal law; and (2) the evidence sufficiently demonstrated causation in fact as to the perimeter-seating claim. Remanded.View "Lake v. The Memphis Landsmen, LLC" on Justia Law

In 2003, Russell, the sole occupant and pilot of an Agusta 109C helicopter, died after his helicopter crashed in Illinois. Russell, a resident of Georgia, was living in Illinois and working for an Illinois air ambulance service operating in the Chicago area. The helicopter was manufactured in Italy in 1989. The trial court dismissed claims against SNFA, a French company that manufactured a custom tail-rotor bearing for the helicopter, for lack of jurisdiction. The appellate court reversed and the Illinois Supreme Court affirmed, noting that Agusta and its American subsidiary, AAC, effectively operated as an American distributor for the tail-rotor bearings in the U.S. market and that SNFA custom manufactured the bearings at issue specifically for Agusta. By engaging a business entity located in Illinois, SNFA undoubtedly benefitted from Illinois’ system of laws, infrastructure, and business climate and has the requisite minimum contacts with Illinois for purposes of specific personal jurisdiction. The exercise of jurisdiction is reasonable; Illinois has an indisputable interest in resolving litigation stemming from a fatal Illinois helicopter accident.View "Russell v. SNFA" on Justia Law

Tiara Condominium Association (Tiara) retained Marsh & McLennan (Marsh) as its insurance broker. Marsh secured windstorm coverage through Citizens Property Insurance Corporation (Citizens), which issued a policy that contained a loss limit in an amount close to $50 million. Tiara's condominium subsequently sustained damages caused by two hurricanes. After being assured by Marsh that the loss limits coverage was per occurrence, Tiara spent more than $100 million in remediation efforts. However, when Tiara sought payment from Citizens, Citizens claimed that the loss limit was $50 million in the aggregate, not per occurrence. Tiara filed suit against Marsh, alleging, inter alia, breach of contract, breach of fiduciary duty, and negligence. The trial court granted summary judgment for Marsh on all claims. The appeals affirmed with the exception of the negligence and breach of fiduciary claims, as to which it certified a question to the Supreme Court to determine whether the economic loss rule prohibits recovery, or whether an insurance broker falls within the professional services exception that would allow Tiara to proceed with the claims. The Court answered by holding that the application of the economic loss rule is limited to products liability cases.View "Tiara Condo. Ass'n, Inc. v. Marsh & McLennan Cos. " on Justia Law

Peter Carter was driving a Ford Explorer rented from Overland West when Todd Durham's vehicle collided with Carter's vehicle. The impact caused the Explorer to roll five times, partially ejecting Carter and killing him. Carter's estate filed a wrongful death and survival claim against Ford, Overland, and Durham (collectively, Defendants) under strict products liability and negligence theories. After a jury trial, the district court concluded that Durham was liable in negligence and that Ford and Overland were not liable. The Supreme Court affirmed, holding that the district court did not err by (1) denying the estate's motion for default judgment on liability as a sanction against Ford for withholding evidence of other incidents; (2) excluding the estate's proffered evidence of other incidents; (3) excluding evidence related to Ford's actions in making a Safe Canopy System a standard feature in the United States in 2007 and some other countries in 2002, and by permitting Ford to present a "consumer-choice" defense; and (4) excluding an indemnity agreement between Ford and Overland and limiting questioning about the agreement and the parties' prior adversarial position.View "Stokes v. Ford Motor Co." on Justia Law

The United States District Court for the Middle District of Alabama, Southern Division certified a question to the Alabama Supreme Court: "Under Alabama law, may a drug company be held liable for fraud or misrepresentation (by misstatement or omission), based on statements it made in connection with the manufacture or distribution of a brand-name drug, by a plaintiff claiming physical injury from a generic drug manufactured and distributed by a different company?" Plaintiffs Danny and Vicki Weeks filed this action against five current and former drug manufacturers for injuries that Mr. Weeks allegedly suffered as a result of his long-term use of the prescription drug product metoclopramide, the generic form of the brand-name drug "Reglan." The Weekses contended that the Wyeth defendants had a duty to warn Danny's physician about the risks associated with the long-term use of metoclopramide and that the Weekses, as third parties, have a right to enforce the alleged breach of that duty. The Supreme Court concluded: "[i]n the context of inadequate warnings by the brand-name manufacturer placed on a prescription drug manufactured by a generic-drug manufacturer, it is not fundamentally unfair to hold the brand-name manufacturer liable for warnings on a product it did not produce because the manufacturing process is irrelevant to misrepresentation theories based, not on manufacturing defects in the product itself, but on information and warning deficiencies, when those alleged misrepresentations were drafted by the brand-name manufacturer and merely repeated by the generic manufacturer."View "Wyeth, Inc., et al. v. Weeks " on Justia Law